gov.uscourts.nysd.447706.1199.3_1.pdf

Case 1:15-cv-07433-LAP Document 1199-3 Filed 01/27/21 Page 1 of 2 Exhibit 1  Case 1:15-cv-07433-LAP Document 1199-3 Filed 01/27/21 Page 2 of 2 Haddon, Morgon and Foreman, P.c Jeffrey S. Pagliuca HADDON M ORGAN 150 East 10th Avenue F OR EMAN Denver, Colorado 80203 PH 303.831 .7364 FX 303.832.2628 www.hmflaw.com [email protected] May 18, 20 16 VIA EMAIL Meredith Schultz, Esq. Boies, Schiller & Flexner LLP 401 E. Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 [email protected] Re: Giuffre v. Maxwell Dear Ms. Schultz: Pursuant to paragraph 11 of the Protective Order in this case Ms. Maxwell disputes the confidential designation of documents produced by Ms. Maxwell to the Plaintiff, GM 748-849. Your email does not provide any good faith basis for the assertion, likely because there is none. GM 748-840 are various police reports that have been publicly available for years. GM 841-849 are public comments about your client's story which are available to the world by a simple Google search. This designation, done without any good faith basis, is another disappointing example of the lack of professionalism demonstrated by Plaintiff in this case. Please withdraw it immediately. Very ly yours, JSP/BR