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S. 151, 108th Cong. (as engrossed in the Senate, Feb. 24. 2003) 7 Robert A. Katzmann, Judging Statutes (2014), at 3 7 iv EFTA00103713 Senator Leahy, Amber Legislation, Cong. Rec. 149:50, 55147 (2003) 7 v EFTA00103714 PRELIMINARY STATEMENT Ghislaine Maxwell respectfully submits this Memorand
DING INDICTMENT AS TIME-BARRED Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: 303-831-7364 Bobbi C. Stemheim Law Offices
w York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C
Ratcliffe "raises concerns that the Administration may be continuing to conduct surveillance operations by relying on Executive Order 12333." Sens. Leahy and Lee wrote, "Congress and the American people have a right to know if this or any other administration is spying on people in the US outside of
her sex crimes case to impose a gag order on lawyers and others to reduce prejudicial pretrial publicity and protect her chances of a fair trial." Jeffrey Pagliuca "filed a letter in Manhattan federal court citing public comments made by Acting U.S. Attorney Audrey Strauss, the head of New York's FBI office and
nd protect her chances of a fair trial." Jeffrey Pagliuca "filed a letter in Manhattan federal court citing
Ratcliffe "raises concerns that the Administration may be continuing to conduct surveillance operations by relying on Executive Order 12333." Sens. Leahy and Lee wrote, "Congress and the American people have a right to know if this or any other administration is spying on people in the US outside of e
r her sex crimes case to impose a gag order on lawyers and others to reduce prejudicial pretrial publicity and protect her chances of a fair trial." Jeffrey Pagliuca "filed a letter in Manhattan federal court citing public comments made by Acting U.S. Attorney Audrey Strauss, the head of New York's FBI office an
and protect her chances of a fair trial." Jeffrey Pagliuca "filed a letter in Manhattan federal court citin
Ratcliffe "raises concerns that the Administration may be continuing to conduct surveillance operations by relying on Executive Order 12333." Sens. Leahy and Lee wrote, "Congress and the American people have a right to know if this or any other administration is spying on people in the US outside of
her sex crimes case to impose a gag order on lawyers and others to reduce prejudicial pretrial publicity and protect her chances of a fair trial." Jeffrey Pagliuca "filed a letter in Manhattan federal court citing public comments made by Acting U.S. Attorney Audrey Strauss, the head of New York's FBI office and
nd protect her chances of a fair trial." Jeffrey Pagliuca "filed a letter in Manhattan federal court citing
Ratcliffe "raises concerns that the Administration may be continuing to conduct surveillance operations by relying on Executive Order 12333." Sens. Leahy and Lee wrote, "Congress and the American people have a right to know if this or any other administration is spying on people in the US outside of
her sex crimes case to impose a gag order on lawyers and others to reduce prejudicial pretrial publicity and protect her chances of a fair trial." Jeffrey Pagliuca "filed a letter in Manhattan federal court citing public comments made by Acting U.S. Attorney Audrey Strauss, the head of New York's FBI office and
nd protect her chances of a fair trial." Jeffrey Pagliuca "filed a letter in Manhattan federal court citing
assim 18 U.S.C. § 3509(aX8) 14 18 U.S.C. § 3509(k) (1990) 8 8 U.S.C. § 1101(a)(43)(M)(i) 12 Pub. L. No. 101-647 8 Other Authorities Senator Leahy, Amber Legislation, Cong. Rec. 149:50, 55147 (2003) 3 iv EFTA00028907 --- PAGE BREAK --- Ghislaine Maxwell respectfully submits this Reply Memo
T OF HER MOTION TO DISMISS COUNTS ONE THROUGH FOUR OF THE SUPERSEDING INDICTMENT AS TIME-BARRED Christian R. Everdell COHEN & GRESSER LLP Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Phone: Attorneys for Ghislaine Maxw
Page: EFTA00028903 →Entities connected to both Leahy and Jeffrey Pagliuca

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSON
Michael Cohen
PERSON
Denver
LOCATION
Prince Andrew
PERSONSouthern District
LOCATIONCohen & Gresser LLP
ORGANIZATION
Colorado
LOCATION
Alison J. Nathan
PERSON
David Boies
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
Bradley Edwards
PERSONthe Southern District
LOCATION
Audrey Strauss
PERSONSecond Circuit
ORGANIZATION
Paul Cassell
PERSON
Bronx
LOCATION
Virginia Giuffre
PERSON
Julie K. Brown
PERSON