UNITED STATES COURT SOUTHERN DIST-4.7RIC13.5T OF NEW Plaintiff7 RESPONSE IN TO MOTION ORDER AND MOTION THE COURT TO DIRECT TO DISCLOSE ALL INDIVID12.3UALS TO WHOM HAS DISS-5.8EMINATED CONF10.8IDENTIAL A HADDON 9AND FOREMAN P.C East th Ave5.1nue De5.5nver CO Case Document Filed Page of i TABLE OF CONTEN4.1TS 10THE DOCUMENTS 9I23SSUE NO5.2T A Plaintiff5.7?s Police5.5 Record-9.3s Are Av ailable 7fr5.7om Enf-6.3o-.3rcement 9Age5.5n-.3cies in F6.2l-.2orida a5.8nd Colorado-13.5 State Statute F5.9o-.3rbids 12Disclosure of the Documents Re-5.6dacted Appro-6.4priatel-21.6y19.6 9the ARGUME-9.5NT 6AS TO A 449.7Plaintiff5.9 F6.1a3.7iled to Move this Court to Uphold Her of Doc5.7u-.1ments as Confidential Plaintiff6.1?s Counsel Ha5.9s Repeatedl-19.1y20.1 and Public This Case Nume-5.2rous Publicl-9.2y20 Ava6i0lable Police6 Reports-8.6 W-5i0th Re dacted J-7.9uvenile Case Document Filed Page of Ghislaine Ms f)6i-.2les this Response 6.8Resp-10onse in Opposition to Plaint8i0ff?s Motion for5.8 Protective Order a6.6nd Motion for the C-10.2ourt to Dire5.7ct to Disclose 11I22.9ndividuals to hom Defe6.3ndant Disseminat-11.7ed Confidential I13n-9for6mation Motion?-7.2 Doc5.8 and stat-10.5es follows:-6.1 INTRODUCTION Plaintiff5.6 does not wa5.4nt to make5.4 public which and 9available to citiz-7.8e3.2n media outlet or who a simple r4.4e3.3quest with the releva5.5n-.3t motive for the informat-9.6ion from the public disc-8.4ernible-6.4 from a simple 9the police5.6 repo-9.2rts pai-11.4n-.2staking8.8 detail the re6.8ports document the Plaintiff?s c5.7laims Ms and ther4.7efore the substantial t-11.5ruth of statements attribu-8.3ted to Ms Max-9.3w-.1ell The police reports among7.6 the re-5.6cords Plaintiff?s lies public documents and is no 9g9.6ood basis for Plaintiff5.9?s to re6.8nder them hidden 9fr5.9om public view in her public 6lawsuit desig6.3n-.7ed to p-11.7romote he6.1r 6we5.1ll-9-orch-9.7e3.1strated medi-11.9a The police r-7e2.8ports as to the late and Plaintiff5.9?s s-7.9ubstantial substance abus-10.3e her lack-9.5 of fa of and sele-7.8ctive use of law enforc-5.6ement the polic-7.6e 8.9re6.4ports demonst ra7.3te tumultuous home life bearing11 no 9re6.8l-11.2a3.8tionship to pr-6ess statements or alleg10e3.8d and providing10 alterna6.8tive c-5.3a3.7usation to of Plaintiff?s clai-9.4med e5.6m-.4otional distress perfe6.6c3.6t sens-9e that Plaintiff5.9 would wa5.7nt to shield from the public these un-9.1flatterin-8.1g9.9 about her5.9 past and curre6.4n-.4t 11circumstanc-5.6e3.4s just because 6a docume-7.6n-.4t is unflattering10.6 does make5.4 it confidential und-7.8er the 9terms of the prot or-5.9der issue in this ca7se Case Document Filed Page of Background Thr oug9.5h sh-10.5eer determination and in the of Plaintiff?s sw-6.2orn denial that she has had any contact 10with law e5.6n-.2for-6.2cement of-6.2f-6.2icials from to the present apart from supposed involvi-4.3ng8.9 Ghislai-12.3n-1.1e counsel Defend-10.1ant unearthed nume-7.9rous of such conta-7.9c3.1ts time pe5.1riod just before and alleged sex-9.4ual 9to Epst-11.6ein and Gh-9.4islaine Plaintiff15.6 intera6.5cted with law enforc-5.8ement on numerou-9.6s Novem12.3b-3.5er Plaintiff5.9 then old was obser4.9ved law 9enfor-6.1c-5.3ement officers d-7.8runk in the a hom-12e durin-20g9.2 the middle of the school She wa5.3s not 9as the Motion claim She wa5.1s obser5.3ved in simulated act with her who then-8.3 old As all of witnesses Plaintiff5.7 had voluntaril-10.5y19.7 made numerous passes at members of thei almost fallen into a ca-5.8nal and then when spotted 9the sch-9.2ool of-6.2ficer to with him in not telling9.8 her she failed to to s-12c3.6hool that Plaintiff6.1 and her old riend verifi-12ed had had interc6.5ourse5.5 in the the report and wa4.7s 10char-7.1ged having7.7 conta-5.5c3.5t with a minor Those were6.5 the false alle-5.5g9.7a3.5tions contact Rather4.7 the to the detox-11.3 unit at the hospital Plaintiff15.7 claimed she4.5 had b-9.4een 14.5assaulted her Plaintiff6.3?.3s-6.5 claim of assault-8.1 wa5.3s 8.9re6.3futed 8.9the witnesses-7,-.5 who v-12.5e3.3rified Plaintiff6.4?s a6.2t.2tempt to 11out of trouble to have with the officer the 9man was with 9ra6.4pe on admitted intercourse5.6,-.2 char-6.2ges a-6.4g9.8ainst him ultimatel-19.4y19.8 De5.1claration of A 7Menninger 6De5.1cl A Consistent with 8F6.1l-.3orida law the 7records 9re6.7da-5.3cted the Sheriff?6.1s the identities a-6nd other5.1 info-7.9r-5.9mation of all juveniles we5ll Plaintiff6.1?s pa5.9re6.9nts January contr-8a3.8diction to Plaintiff6?s sworn testimon-11.3y19.7 that she fr5.5om home at the of lived on the st re5.8et for months w5.2i-.2thout word fr6om her and ultimatel-9.5y19.7 the in a SW-5.4AT from the clutches of named Ron Eppin-10.4g9.6er the police5.4 document-9.6e3.5d 9a call fr5.8om Plaintiff5.8?s mom that she ran from due to her4.8 9re6.6cent a5.6ttitude us-11e and 9?possi-4.4ble cult-4.4 wa5.8s found f5our late-6.2r her br5.7other 9and r-6.3e3.5turned her who ha5.5d to involuntaril-13.5y15.2 place her in a drug9.9 No reference to Ron Eppinger)6,0 an SW-5.2AT r6a3.8id or months without conta-7.6c3.4t are refl-8.6ected in the reports.-21.6 Case Document Filed Page of This repor the Palm Sheriff-6.2?-.2s documents Plaintiff5.9?s sec-5.3ond false alle-5.3ga tion of assault in a f5our month period Plaintiff5.4 during10.4 four wa5.2s f-6.6rom home asked-6.6 to out with two 7male frie4.7nds of After ten-month investig9.9ation which inclu-9.1ded 5.5line-ups witness inte-5.5rviews and othe-7.5r police investig10ation the prose-6.2c-5.2uting10 authorities decided 7against filing8 the two based on Plaintiff6.1?s lac6.3k no substantial likel ihood of succ6.2ess at Consistent with F5.9l-.5orida law the 7records 9re6.5dacted the 9and information as pertains Plaintiff6 These same 9re6.7ports docu-9.1ment that Plaintiff5.9 wa5.7s a 6re6.7sident a 9re6.7h-9.1a3.7bilitation 9from at least 12Fe Decemb-11.9e-6r wher-6.9eas she sworn in deposition testimon-11y30,0 aff6i-.2davits in and in the Complaint in t5.8h0is case that she a to Epstein in June Plaintiff fianc Mich-9.6ael Au-9.6strich c5.2a3.2lled the police5.2 9after Plaintiff5.7 and her enter4.7ed the 7apartment and the pun-7.3ched Austrich in the face Plaintiff5.5 9fled the s-8.3cene with 7prior to the arr5.7i-.5val of the polic-7.5e The documents 10that Plaintiff5.7 had a fianc in or around 9she c6.5laims she slave to Epstei-9.6n that she lived in an apartment and that she and we5.4nt with her including7.8 the of D5e3.7cl Plaintiff6 wa5.8s not a claime-7.2d victim of this August Plainti5.4ff5.6 then a 9we5.4ek her th birthda-6.6y19.6 called police 9a theft of 8cash her shirt in her a she hosting7.4 a number of 6fr5.4iends police took a report fr-6.6om Plaintiff5.9 questioned her friends but fail ed to apprehend a suspe-7.7c3.3t De5.6cl This report is the time Plaintiff5.8 wa5.2s a slave to Epst-11.8ein The d-8.6o-.6cuments that she wa then being7.9 ca5.7ptive Epstein wa5.7s living7.9 inde-7.3pendentl-13.3y19.9 in apartmen-6.1t with her 7and anothe-7.8r f5.4r-.6iend a nd she possessed the whe5.8r0ewithal at 5.5that time to contac5.8t law enfor-6.6ceme-7.8n-.6t for perceived criminal law violations.7.3 March Plaintiff6.1 then 9with theft from her the Roadhouse Grill Ac-5.6cording7.6 to the pol and court records Pl-11.6aintiff left mid-shift at approx-6.1imatel-9.3y19.9 p.m and all of the from tip jar 6De5.5cl The 9re6.7ports contr-8.2a3.6dict Plaintiff5.8?s claimed she was as a 6wa5.3itre6.4ss 11at the same time also sh-9.2ow that Pla-5.8i-.4ntiff had an for at the time she moved to Austra6.7lia in September 9.2Plaintiff5.9 wa5.7s not a juvenile at the time a5.5nd wa5.5s as an June Police re6.2port reflects Plaintiff6.2?s c6a4ll a civil assist Plaintiff6.2 old 9complained-7.5 that her then landlord her 6.7abandoned-9.7 out as after she5.5 mo-11.3ved to a ne5.5w The landlord said she had abandoned the items and 9as she left 7can ke-5.8ep the b-9.6a3.2stard Case Document Filed Page of the polic-5.8e documents that-9.4 neither the re6.2siden-8.6ces she was fr6om or to involved the a-5.2p0artment Plaintiff6 claims wa5.8s re5.8nted 7for6 Epstein and she te-7.7stified she lived J-9.3une until September Decl Plaintiff)6 was not a juvenile a5.2nd the 7case not documented as crime.-6.7 in Colorado reco-9.8rds ect that Plaintiff6 and her husband we5.5nt to a in the middle of be-5.4came a5.5nd re6.5turn-8.3ed home wherein invol-8.9ved in a 11reg8.9a-6.3rding the of the dog8.9 Mennin-12.1ger De5.6cl Plaintiff)5.8 alleges assaulted 6husband as witnessed at le-5.6ast one of their 9ch-9.4ildren 8.2Plai husban-9.1d-.1 wa5.7s with dome-5.3s0tic violence pled 9and wa5.5s pla-5.5ced on 9probation-9.5 De5.7sig6.9n-9.1ation as Confident-11.3ial After production of the police5.5 repo-9.3rts pursuant to Rule disclosures Plaintiff6.2 a6 letter5.2 the 7Doc5.5u-.3ments be Confidential Counsel for Ms 9re6.5sponded the documents are6.6 9available a5.6nd ther4.2efore hould not be as Confid-11.6ential See of 9Mer6e3.8dith Ex-8 W-5h.2ile Plaintiff6.2 wr5.2ote a6 letter5.2 outlining10.2 the sa me 7fr5.9ivolous legal she incorpora6.7t-11.3e3.7s here6.2 and 9as addr-6.6essed below 6c-5.6ounsel neve5.3r 6acquiesced 9to and she fa6.3iled to pursue a judici-11.7al determination of the mat-11.4ter until Aug9.8u-.2st three months later thus Plaintiff5.8 has waived 9claim of I THE DOCUMENTS AT ARE NOT A Are Avail-4.6a-1.4ble Age6.3n-2.3cies in F11.3l.3orida and Colorado-7 p-9.3r-.3ivate media outlet or public 9can obtain the repo-9.3rts at issue interposin-9.5g9.5 a si-12.7mple request to the 7.1law and applicabl-12.9e2.2 Case Document Filed Page of and action fees As such there is no privac-13.4 inte-5.4 st in pre6.7 rving10.8 thes-8 documents obtained in such shion as 223Confidential unde5.3 the Prot-8.7 ective Order eed in the rk ily5.1 ws appare6 ntl-24 obtained police ports conc-5.4 ernin-8.2 Plaintiff5.8 2s lse claim of a ssault from rua6.3 interviewe5.3 one the two accus-10.5 the er for the ot and publi-16.2 shed subst-3.4 detail-3.4 obtained om the police ports See Oren niv Alle-7.3 slav-5.7 pste in Prince Andre-5.7 accused e3 of pe in but was found not cre6.3 dible rk ws eb ws.com/news/world/s-10 slave-prince-andr-7.2 last access-11.6 e3 Feb Remarkabl)-22 Plainti-4 couns-10.1 provided an interview that artic-5.9 le nd ve curate char-6.7 acte-7.9 ization-9.4 of the prosec6.1 utin-9.7 authorit-12.4 2s finding8.8 id the pros-7.4 ecutor-8.6 to describe not edible mea5.3 ns that did not think suff5.1 ent evid to win But she the er id in a statement Unfortun-11.9 counsel 2s acteriz-7.7 ation of the police5.3 repo-9.5 rts is dire6.3 contradicted the polic-7.8 reports themselv-11.6 which ound that Plaintiff5.9 ked edibilit-11.3 and there a eason-11 le probabilit-14.2 of su-8 ccess at trial Compare id Menninger Decl G6 223this se is no filed due to ictim 2s lack of edibilit-11.3 and no substantial likelihood of succ6.7 ess at ial The pros-7.1 ecutor not counsel clai-9.5 med in the ws article that cked ufficient eviden-10 ce to Now Plaintiff6.2 coun-9.3 sel having9.7 put own lse public spin on the Palm authorities findin-9.1 wants to preclude others rom correcting9.6 public record with the actual findin-11.4 contain-9.4 ed in the repo-9.4 rt The cords are not confi-12.3 ential bec4.7 th essibl-17.7 public can be nd have en ccess-11.5 the media and Plaintiff13.5 2s counsel has inaccurat-11.9 characteriz-7.9 the Case Document Filed Page of finding9 Plaintif-6f0?6s.2 credibilit-11.2y20 to the media and thus cannot be to complaint that the ex-9.4posing9.6 should be kept from the p-9.5ublic No State Stat5.9ute6.7 Dis closure the is no mer5.4it to Plaintiff6.4?s mislea5.3ding and groundless ar-6.4gument that various F5.7l-.7orida 9.7and Colorado statu-7tes forbid di of the police They20 do not Plaintiff6.3 cites sec6.1t.1ions Statutes and 5.2and Colora6.8do Revised Statutes et seq as support her None5.3 of these st-12.7atutes support her F5.8l-.6orida Section does not to 6.5the Do-9.5cuments That provision re6.3lates records the 7F6l-.4orida D-7e3.6partme-6.4nt of Children and F6a3.6mili es Each at issue is stamped prominentl-13.7y19.5 9as Certified the Palm-7.9 Offi-8.6ce Menninger4.8 Decl None5.6 the were6.6 obtained 9fr5.8om the De5.6partment of Children and F5.9a3.5milies Section relates to ecords held that D-7.2e3.4partment related to child abuse and None of the do cument-9.7s-.3 re5.3lates to child abuse Section ex-9.5empts8.7 from ope5.3n laws vid-11e3.8otaped-7 stateme5.9n0t of a minor who is allegedl-11.4y19.8 victim of battery F6i-.4rst ther4.7e is no vid-11.3eotaped statement Plaintiff5.9 contained within the Documents.-6.3 F6.1la 6Second 6.7the prohibitions the identity of the a6.1l.1leged victim See id subs-11ection the identity of a person who a victim of sex-6.9u al offense-7.4 ex-10.3empt from open-r-6.8ecords laws Here)6.4 the 9obtained identity copies of the police5.6 9reports and disclosed them to Plaintiff6.2 the Sher5.2iff co-9.3mpleted a5.6nd provided a with a list of state re6.5quirements 9r-6.3e3.5daction and 9consistent wi th their the indicating9.8 cited-6.3 Fla Stat is st-9.5atu5.7te Case Document Filed Page of dactions pursu-8.3 nt to entit-11.5 of victim of ual batter4.7 lewd and lascivious offe6.2 nse upon a person ss than-5.8 ars old child-9.6 abus al offens-11 Menninger Decl and Accordin-11.2 the riff did not violate section produ-9.2 identit-13.4 cted opies police reports erning Plaintiff5.8 lorida Statutes Section and a pertain to juvenile-justice5.4 cords none of hich are6.5 includ-9.3 within the Documents-10.1 ct a 223child is fi-9 ned at sub section to appl-9.5 to mea5.5 person er the of on who is all eged to have committed violation of law urrin-8.3 prior to the time that person reached the of ears Th-8 ecords aining10 to Plaintiff6 2s missions of rimes she5.7 rs old rida Stat None5.4 of the cu ments are6.1 juvenile-justic-7.9 reco-9.7 rds police reports inall-11 ection bears no leva5.3 ce to the orida cuments statute cre6.2 a cause of action a al ime victim against person 223prior to open judicial proceedin-12.6 communic-5.8 tes 223the addr-6.6 ess or other spec6.2 ic identif-18.6 inform-11.8 tion concernin-8.2 the ctim The statute is irr5.8 ant One5.6 the entif-16.2 nformation in the police reports in this case-6.7 redacted and theref-6.5 ore not communic-7.7 ted to No 223name ss or othe-6.4 pecific identif-16.2 information is contained in the documents Two the case at bar is an judicial proceedin-11.9 volving10.1 Plaintiff6.1 as a son who falsel-20.1 has claimed to be a ual sault crime victim-4.6 a num ber of such en judicial proceedin-11.9 ve preced-10.1 ed one and cording6.9 the atut-4.3 is appli-4.3 cable Miam2.5 i ld Publ 2g happell 2d la pp Case Document Filed Page of Colorado Statutes Plaintiff6 also cites Colorado statutes whic she5.6 ims support the propositi7.6 on that her identit-13.3 as the victim of domestic violence is ected Colorado It is not ection is a testimoni5.8 al privilege5.8 statute not a document-confid-8.4 ntiali statute That provision for6.2 bids a victim 2s advocate om bein-9.5 quired to testif-16.5 ning7.5 communica5.8 tions with an alleged victim of domesti violence or assault one has ht testimon-8.7 om victi-10.9 2s advocate in thes-8.6 ceedin-11.8 The a3 do cuments also not contain Plaintiff6.1 2s mmunica5.9 tions to vict-9.1 im 2s dvocate Mennin-11.3 ger cl Plaintiff lso cites Color-5 ado Re6 Stat6.2 and for6.1 the proposition that the identities of her hildren cannot be disclosed se provisions maintain-3.7 the confidentialit-21.6 of cords rtainin-9.2 to juvenile justice5.6 actions against children The docum-11.7 ents at issue do not late to ch action;-11.4 the hildren were6.6 witnes-7.6 ses to an alleg10.2 e4 crime committed Plaintiff6.5 2s husba5.4 nd he not the subjects criminal tion them-9.5 selves.-6.9 All Doc5.3 ments dacte6.3 Appropriately By the Age5.2 The police ports from orida that rtain to juveniles who alle-5.6 ctims of criminal sex-8 ual conduc5.8 opposed to Plaintiff 2s own criminal conduc5.4 as an adult and her quest for civil assist as an adult were)6.4 ed onsistent with Florida law ndeed both ports where6.6 in she alle-5.4 tions of ual misconduct provided along7.8 with a klist demonstrating9.5 that the nfor-6.5 cement dacted the ports consist-12.7 nt with orida The orida ts the identit-11.6 of the alle-5.6 victim and the police5.4 orts produced ant all identi-11.6 edacted Mennin-11.3 cl and and icti-9.5 cate all not as to mm un7 ion7 to su7 h7 v7 2s ad-6 v7 cate a victi-9.2 tic olen6.5 a al lt pers or rou7.5 ia tten7.5 records or reports Case Document Filed Page of Plaintiff5.4 has not cited the dacti-14on of information from Colorado police II HAS ANY TO CONF10.7IDENTIALIT-8.6Y A F11.6a.8iled to Move6 this Court U-6.6phold 10Her6 De6sign-5.6ation the as Conf-5.9iden6.3tial The Protective Ord-9.8e3r in case puts onus on 10the pe5.1rson 9a C-8.3o-9.7n-.7fidential desig9.9n-.1ation to resolve the matter)4.9 with opposing9.9 or se)5.7ek Court resolution The Protective Ord-9.8e3r 6at provides:-9.2 the p-9.3a3.5rties cannot the objec5.5tion within ten business the time the notice is it shall be the of the the information as to file an 9appro-6.2priate motion requestin-9.2g9.8 the Court deter4.8mine the disputed information shoul-12.5d be subject to the terms of this Protective Order If such a motion is time5.8ly filed the disputed information shall be treated 7as under the of this Protective Or4.6der until the Court rules on the motion If the designating party fails to file such a m12.3o.1tion within the presc5.9r.3ibed time the disputed informati-11.2on shall lose its desig10n0ati-13.2on as 9and sh-10.4all not there6.4a3.4fter as with P-7rotecti-4.4ve D4.8oc is undisputed that the 6challen-9.1g-.1ed Plaintiff5.9?s of the as Confidential on and it is also undisputed that the pa5.7rties not resolve the objec5.5tion within ten after notic-6.5e of the obje-7.5c tion wa5.5s Pl-16.3aintiff did not file a motion requesting9.9 the Co-10.1urt to deter4.9mine the mater4.9ial should be to the Protective Order for three7 9months hence she did not file a motion within the pre6.6scribed time a5.5nd the Protective Orde-5.6r now4.8 co-9.4mmands that th disputed information shall lose its desig9.8n-.2ation as Confidential a5.5nd shall 10not there6.6a3.5ft-8.5er tr-8.3eated Confidential P12.2l1.2aintiff?s and P12.2ublic5.2ly In This Case Numerous 10P10.9ublicly Available P12.9o.1lice Redacte6.9d-2.7 Juve-14.2nile 9complete c6ontr-7.8a4diction to her leg10.2a4l position in this Motion P6.3laintiff6.2 and her c7ounsel have 9.6filed in public doc5.3uments associa with this case police r-6.6e3.2ports from Case Document Filed Page of pertaining9.8 to of abuse Epstein Plaintiff6.1 filed her R-11.9e3.9sponse in Opposition to the Motion to D5.3oc then again on and on Doc5.6 Doc5.6 and Plaintiff)5.9 file-5.3d on ECF Palm Po-9.1lice De5.7pa-5.3rtment re6.7ports that contain to alle-5.3g-.1ed juvenile 7victims of miscon10.9duct with the na5.7mes of the victims re6.9d-8.9acted Plaintiff5.8 b-9.2e3.6lieves that police5.6 with redacted information as these 9?confid-8.4e-5.6ntial she been 9the one5.4 to publicl-9.6y19.6 disseminate such Where6.4 did she obtain these4.4 10Was it of 6?sealed juv-9.5e3.3nile for to those police would seem the juvenil-11.3e3.7s in the filed Plaintiff5.9 juve-7.3niles who have lawsuits juveniles who have paid hundr-8.5eds of thousands of dollar4.9s the tabloids for4.9 their st ori-11.5es ar5.7e 8.6entitled more pr-6.3otec5.5tion fr5.7om publicit-13.1y20.1 than is Plaintiff6.1 He5.9r position that police6 8.9re6.9ports 8.9should be kept Confidential is belied 9her ow5n public c-5.5ourt in this CONCLUSION Ms Maxwe5.3l-.7l requests 5.5the Court e-5.7n-.5force Protective Plaintiff6.1?s motion to 9available polic-8e reports Con-9.8fidential 7under the ter4.2ms of Protective Orde-5.6r in this ca6.5se and 6attorne-15.6y fees and 9costs-4 associated-8.1 with of this Response to Ms Case Document Filed Page of Da6ted Respec7tfull-12y20.2 submitted,-13.4 Laura A Menninger A pro hac 10vice ADDON ORGAN OREM-9.5AN P.C East th Ave5.1nue De5.5nver CO Phone Fax-14 lmenning7.4er-6.6 hmflaw.c5.2o-9.6m Attorneys for Ghislaine Case Document Filed Page of CERTIF11.4ICATE SERVI-7.9C2.8E that on ser5.7v-.3ed this De5.7fendant?s R-9.3e3.7sponse in Opposition to Plainti5.8ff?s 12Motion for Protec5.8tive Or-7.8der and Motion for the Court to Direct De5.8fendant to Disclose Individuals to 12W23hom Defendant Has Disseminat-11.2ed Confidential Information via ECF5.4 on the Sig8.1r.1id McCawle-15.1y7.4 Mer7.1e4.9dith Schultz-7.4 LEX-13.3NER East Olas Ste smccawle-15.8y19.4 7bs-9.4fllp.com mschultz-4.9 bsfllp.com9.5 Paul Cassell-6 Universit-11.7y19.5 Street Salt UT cassellp law.utah.-9.7e3.1du Edwards F6.6A.6RMER 7.2EDWARDS FI13.9STOS North Andrews Ste brad pathtojustice5.5.com-14.1 S7.2tanley21 Twin Rd South Salem NY StanPotting10.1e3.9r aol.com Nicole Simmons Nicole Simmons5.7 Case Document Filed Page of
