Epstein Secrets

attention to page 5 of the joint letter, in which Menninger wrote: Indeed, this Court rejected Ms. Maxwell's argument that certain portions of the Response and its exhibits should be unredacted because the material had already been made public. See Dkt. No. 168 at 2-3; Letter Motion of Laura A. Menning

et them know. Thanks, ■ From: Nicole Simmons < Sent: Thursday, April 1, 20217:29 PM To: 'Nathan NYSD Chambers' < MI> Cc: Laura Menninger <M I>; Jeff Pagliuca Ma'; >; 'c >; (USANYS) ‹ > Subject: U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN) [Joint Letter re. Redactions to Omnibus Resp. & Ex. 11] Dear Jud

Chambers' < MI> Cc: Laura Menninger <M I>; Jeff Pagliuca Ma'; >; 'c >; (USANYS) ‹ > Subject: U.S. v.

say without applicable exceptions, or based on other evidentiary grounds. Those issues will be argued at the appropriate time. For purposes of this Response, Ms. Maxwell simply notes the fundamental errors in the Notice, failure to comply with the rules, and general principles that make the residual hea

X 15-cv-07433-RWS RESPONSE TO PLAINTIFF'S NOTICE OF INTENT TO OFFER STATEMENTS UNDER, IF NECESSARY, THE RESIDUAL HEARSAY RULE Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 EFTA00617178 Defendant Ghislaine Maxwell ("Ms. Maxwell") hereby

DUAL HEARSAY RULE Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 Ea

irm that that his communications with Plaintiff regarding "media issues" were primarily for the purpose of providing legal advice. According to the Response "Ms. received legal advice from Mr. Pottinger regarding how to handle media inquiries in such a way as to not jeopardize her position in ongoing li

VILEGED DOCUMENTS Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN. P.C. East 101h Ave

GHISLAINE MAXWELL, Defendant. X 15-cv-07433-RWS DEFENDANT'S REPLY IN SUPPORT OF MOTION TO COMPEL NON-PRIVILEGED DOCUMENTS Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN. P.C. East 101h Avenue Denver. CO 80203 EFTA00618132 Case 1:15-cv-07433-RWS Document 191 Filed 06/06/16 Page 2 of 1

I. The Government's Response to Maxwell's Motion. Confronted with evidence of AUSA misrepresentations to Judge McMahon, the government has filed a Response reluctantly admitting that the U.S. Attorney's Office had sustained contact with Boies Schiller in 2016. Even so, the government tries its best to m

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

constitutes an impermissible constructive amendment and variance to the Indictment. Finally, what is clear from the government's proffer in their Response, the anticipated testimony o will serve as an improper constructive 13 EFTA00090739 amendment to, and an impermissible variance of, the Indictm

NITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL'S REPLY IN SUPPORT OF HER MOTIONS IN LIMINE Jeffrey S. Pagliuca Laura A. Menninger HADDON MORGAN & FOREMAN P.C. Denver Phone: Christian R. Everdell COHEN & GRESSER LLP New York NY Phone: Bobbi C. Stemheim

IN SUPPORT OF HER MOTIONS IN LIMINE Jeffrey S. Pagliuca Laura A. Menninger HADDON MORGAN & FOREMAN P.C.

the court, the use of the qualifier made the question fundamentally ambiguous requiring dismissal of the count. The government, at page 133 of its Response, incorrectly suggests that the burden was on Ms. Maxwell or her counsel to clarify the confused questions, particularly regarding the infinite time

ELL'S MOTION TO DISMISS COUNTS FIVE AND SIX OF THE SUPERSEDING INDICTMENT BECAUSE THE ALLEGED MISSTATEMENTS ARE NOT PERJURIOUS AS A MATTER OF LAW Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim

RE NOT PERJURIOUS AS A MATTER OF LAW Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C