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Case 1:17-mc-00025-RWS Document 36 Filed 03/20/17 Page 1 of 7
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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..
.............................................
BRADLEY J. EDWARDS,
Plaintiff,
v.
17-mc-00025-RWS
GHISLAINE MAXWELL,
Defendant.
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Defendant’s Sur-Reply to Supplemental Reply
Jeffrey S. Pagliuca
HADDON, MORGAN AND FOREMAN, P.C.
150 East 10th Avenue
Denver, CO 80203
303.831.7364
Case 1:17-mc-00025-RWS Document 36 Filed 03/20/17 Page 2 of 7
INTRODUCTION
Almost one year after being served with a subpoena to produce documents in this matter
Mr. Edwards, for the first time, claims, with no real legal support, that the letters he sent to
various former employees of Jeffrey Epstein and other potential witnesses are “work product”.
Mr. Edwards attempts to obfuscate the issue by claiming that he would have to review hundreds,
no, thousands, of emails to determine to whom such solicitations were sent. Mr. Edwards knows
that he sent a form soli
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