Epstein Secrets

States Attorney's Office Southern District of New York Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon. Morgan and Foreman, Pc Laura A. Menninger www.hmftaw.com I write pursuant to the Court's Order of November 23, 2021 directing a supplement to the disclosure for Cer

ic Examine expert opinion to the extent he intends to offer rebuttal testimony to any opinions offered in the government's original disclosure for Stephen Flatley, dated September 15, 2021. I note that yesterday you provided a supplemental notice for Mr. Flatley. That supplement was untimely. Thus, we intend

ct of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon Morgan and Foreman, P.0 Jeffrey S. PairBoca 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com [email protected] Defe

imits to the information that can be gleaned from the metadata. Mr. Kelso may testify in rebuttal to any testimony offered by the government through Stephen Flatley. As trial preparation proceeds, the defense will update the topics for Mr. Kelso if any arise. F. John Lopez Mr. Lopez was a Special Agent with th

fice Southern District of New York New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon, Morgan and Foreman, P.0 Jeffrey S. Pagliuca Denver, Colorado 80203 PH FX www.hmflaw.com [email protected] Defendant Ghislaine Maxwell through counsel, submit

imits to the information that can be gleaned from the metadata. Mr. Kelso may testify in rebuttal to any testimony offered by the government through Stephen Flatley. As trial preparation proceeds, the defense will update the topics for Mr. Kelso if any arise. F. John Lopez Mr. Lopez was a Special Agent with th