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Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 26 of 27
Motion to Enforce the Court’s Order and Direct Defendant to Answer Deposition Questions
Filed Under Seal. Further, because Plaintiff brought this Motion without a valid basis to assert
that she refused to answer any question that was (a) within this Court’s Order and (b) not already
responded to either at her first deposition or during this deposition, Ms. Maxwell requests that
the fees and costs associated with defending this Motion be imposed on Plaintiff, her counsel or
both.
Respectfully submitted,
/s/ Jeffrey S. Pagliuca
Laura A. Menninger (LM-1374)
Jeffrey S. Pagliuca (pro hac vice)
HADDON, MORGAN AND FOREMAN, P.C.
150 East 10™ Avenue
Denver, CO 80203
Phone: 303.831.7364
Fax: 303.832.2628
Imenninger@hmflaw.com
Attorneys for Ghislaine Maxwell
24
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Document Details
| Filename | Giuffre_Maxwell_Batch3_p00332.png |
| File Size | 157.7 KB |
| OCR Confidence | 95.1% |
| Has Readable Text | Yes |
| Text Length | 840 characters |
| Indexed | 2026-02-04 12:39:56.215812 |