Epstein Secrets

merica,' he said." However, the Washington Post <https://www.washingtonpost.corn/world/2020/10/23/trump-biden-netanyahu- call-sudan-israel/> (10/23, Berger, 14.2M) reports that during a call with Netanyahu, "the conversation took a turn when Trump pivoted from the day's diplomatic development to ask Net

Bloomberg, "The government's failure to provide the evidence makes it impossible for Maxwell to prepare her defense, the British socialite's lawyer Jeffrey Pagliuca said Friday in a letter to U.S. District Judge Alison Nathan." As an illustration, the indictment does not provide exact "dates for when Maxwell co

ration, the indictment does not provide exact "dates for when Maxwell committed the alleged crimes, only saying they occurred between 1994 and 1997, Pagliuca said." He wrote, "Neither the indictment nor the discovery inform Ms. Maxwell about critical information necessary to prepare her defense." Teenag

rael today. This allows for direct and shorter flights between Israel and Africa and South America,' he said." However, the Washington Post (10/23, Berger, 14.2M) reports that during a call with Netanyahu, "the conversation took a turn when Trump pivoted from the day's diplomatic development to ask Ne

Bloomberg, "The government's failure to provide the evidence makes it impossible for Maxwell to prepare her defense, the British socialite's lawyer Jeffrey Pagliuca said Friday in a letter to U.S. District Judge Alison Nathan." As an illustration, the indictment does not provide exact "dates for when Maxwell com

ation, the indictment does not provide exact "dates for when Maxwell committed the alleged crimes, only saying they occurred between 1994 and 1997, Pagliuca said." He wrote, "Neither the indictment nor the discovery inform Ms. Maxwell about critical information necessary to prepare her defense." Teenag

29 EFTA00077572 Table of Authorities Cases Abdell v. City of New York, No. 05 CIV. 8453 KMK JCF, 2006 WL 2664313 (S.D.N.Y. Sept. 14, 2006) 8 Berger v. United States, 295 U.S. 78 (1935) 24 Brady v. Maryland, 373 U.S. 83 (1963) 11 Brown v. Maxwel, 929 F.3d 4 (2d Cir. 2019) 19, 20 Chemical Ban

UNDER THE DUE PROCESS CLAUSE TO SUPPRESS ALL EVIDENCE OBTAINED FROM THE GOVERNMENT'S SUBPOENA TO BOLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Christian R. Everdell COHEN & GRESSER LLP 800 Third Ave

ER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C

UNDER THE DUE PROCESS CLAUSE TO SUPPRESS ALL EVIDENCE OBTAINED FROM THE GOVERNMENT'S SUBPOENA TO BOLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim

tor] is in a peculiar and very definite sense the servant of the law, the twofold aim of which is that guilt shall not escape or innocence suffer." Berger v. United States, 295 U.S. 78, 88 (1935). Moreover, "[i]n light of the prosecutor's public responsibilities, broad authority and discretion, the pr

UNDER THE DUE PROCESS CLAUSE TO SUPPRESS ALL EVIDENCE OBTAINED FROM THE GOVERNMENT'S SUBPOENA TO BOLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Sternheim Attorneys for Ghislaine Maxwell

01 --- PAGE BREAK --- Table of Authorities Cases Abdell v. City of New York, No. 05 CIV. 8453 KMK JCF, 2006 WL 2664313 (.=. Sept 14, 2006) 8 Berger v. United States, 295 U.S. 78 (1935) 24 Brady v. Maryland, 373 U.S. 83 (1963) 11 Brown v. Marcel, 929 F.3d 4 (2d Cir. 2019) 19, 20 Chemical B

aw or factual matters which it believes the court overlooked and that might reasonably be expected to alter the court's decision." United States v. Berger, 188 F. Supp. 2d 307, 328-39 (S.D.N.Y. 2002). But "[t]he standard for granting a motion for reconsideration `is strict.' Fanner v. United States, N

t, no later than October I I, the government disclose the specific co-conspirator statements it intends to admit at trial. Respectfully Submitted, Jeffrey S. Pagliuca CC: Counsel of Record (via ECF) EFTA00029594