gov.uscourts.nysd.447706.1330.9.pdf

Case 1:15-cv-07433-LAP Document 1330-9 Filed 01/05/24 Page 1 of 6 COMPOSITE EXHIBIT 1 (File Under Seal)  Case 1:15-cv-07433-LAP Document 1330-9 Filed 01/05/24 Page 2 of 6 Haddon, Morgan and Foreman, P.C Laura A. Menninger HADDON MORGAN 150 East 10th Avenue FOREMAN Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 [email protected] August 16, 2016 VIA EMAIL Sigrid S. McCawley Boies, Schiller & Flexner LLP 401 East Las Olas Blvd., Suite 1200 Fort Lauderdale, FL 33301 [email protected] Re: Giuffre v. Maxwell, Case No. 15-cv-07433-RWS Dear Sigrid: Attached please find documents produced pursuant to a subpoena duces tecum issued to Mar-a-Lago Club, Inc., on July 14, 2016 which have been Bates numbered Mar-A-Lago 0075-0595. Also attached are two documents Bates numbered GM_01141-01144. These emails were collected as responsive to Plaintiff’s First Request for Production of Documents in February 2016 but through clerical error were not produced at that time or following the Court’s in camera review in April. A recent review of documents revealed the error. Sincerely, HADDON, MORGAN AND FOREMAN, P.C. /s/ Laura A. Menninger Laura A. Menninger  Case 1:15-cv-07433-LAP Document 1330-9 Filed 01/05/24 Page 3 of 6 ________________________________ From: Ross Gow Sent: 10 November 2015 18:16 To: Gmax; Philip Barden Subject: Fwd: Inquiry from The New York Times Hi Ghislaine and Philip Please advise how you wish to respond... Best Ross ---------- Forwarded message ---------- From: Meier, Barry Date: Tuesday, 10 November 2015 Subject: Inquiry from The New York Times To: Mr. Gow, Good day. I am a reporter for the Times and it is my understanding that you represent Ghislaine Maxwell. I am working on an article about the legal fallout from the Jeffrey Epstein case. I anticipate mentioning the lawsuit filed earlier this year by Virginia Roberts Guiffee against Ms. Maxwell. How does she respond? Kindly advise by close of business Thursday, November 12, 2015. And call me if you have any questions. Regards, Barry Meier -- The New York Times 620 Eighth Avenue New York, NY 10018 1 CONFIDENTIAL GM_01141  Case 1:15-cv-07433-LAP Document 1330-9 Filed 01/05/24 Page 4 of 6 -- Ross Gow Managing Partner ACUITY Reputation 23 Berkeley Square London W1J 6HE  www.acuityreputation.com<http://www.acuityreputation.com/> The information contained in this e-mail and any attachments is confidential and may be privileged or otherwise protected from disclosure. It is intended solely for the attention and use of the named addressee(s). If you are not the intended recipient, dissemination, copying or use of this e-mail and any attachments in whole or in part is prohibited. 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Please consider the environment before printing this email. 2 CONFIDENTIAL GM_01142  Case 1:15-cv-07433-LAP Document 1330-9 Filed 01/05/24 Page 5 of 6 From: jeffrey E. <[email protected]> Sent: Wednesday, April 22, 2015 3:58 PM To: 'Ghislaine' Subject: Re: ATTORNEY-CLIENT PRIVILEGE ok On Wed, Apr 22, 2015 at 5:46 PM, Ghislaine <[email protected]> wrote: I would like Barden to reply to one further allegation in this bullshit She says Epstein and Maxwell asked her > to have a child for them and to sign a document signing away > the rights to the child in the event that she and Epstein > had a falling out. She says she refused this > request.· Regarding further detail of the interview which I have reviewed I would like to add one further point to underscore the lack of probity in Ms Roberts claims At no point in Ms Maxwell’s life has she ever contemplated thought or wanted to bring up someone’s child as her own and or ask the mother to sign her rights away to the child. In fact the mere idea of such a suggestion is abhorrent. Further, the idea that Ms Maxwell would contemplate an arrangement with someone who abused drugs and alcohol contemporaneously and who was living with her fiancé beggars belief. No document has ever been contemplated, created nor lawyer nor other approached to write such a document at anytime THE TERRAMAR PROJECT FACEBOOK TWITTER G+ PINTEREST INSTAGRAM PLEDGE THE DAILY CATCHthe From: J Jep Date: Wednesday, April 22, 2015 at 15:08 PM To: Gmax Subject: Fwd: ATTORNEY-CLIENT PRIVILEGE 1 CONFIDENTIAL GM_01143  Case 1:15-cv-07433-LAP Document 1330-9 Filed 01/05/24 Page 6 of 6 She says Epstein and Maxwell asked her > to have a child for them and to sign a document signing away > the rights to the child in the event that she and Epstein > had a falling out. She says she refused this > request.· -- please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved 2 CONFIDENTIAL GM_01144