Epstein Secrets

ntive motions relating to the admissibility of expert testimony, deposition testimony, and the admissibility of evidence remained unresolved. Judge Sweet had yet to rule on evidentiary challenges to thousands of deposition questions and answers contained in dozens of bankers boxes wheeled into his cou

CO 80203 Phone: 303-831-7364 Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100 Attorneys for Ghislaine Maxwell EFTA00

eview of the docket, unfortunately, reflects over one-thousand entries. The parties disagreed about the scope and meaning of virtually all of Judge Sweet's discovery orders, including those related to Ms. Maxwell's depositions. Significantly, Judge Sweet's Order prefaced all the listed categories with

T 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 Attorneys for Ghislaine Maxwell EFTA00097378 TABLE OF CONTENTS TABLE OF CONTENTS i TABLE OF AUTHORITIES ii

ity to be heard, but also by affirmatively misleading Chief Judge McMahon, 2 To this day, Judge Preska—who is presiding over the action since Judge Sweet's passing and is addressing the Protective Order on a daily basis as the parties brief what material should be unsealed—apparently does not know th

UBPOENA TO BOLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Mennin • er Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Sternheim Law Offices of Bobbi C. Stemheim Attorneys for Ghislaine Maxwell EFTA00097649 TABLE OF CONTENTS TABLE OF CONTENTS ii TABLE OF AUTHORITIES ii

Jeffrey S. Pagliuca Laura A. Menninger HADDON MORGAN & FOREMAN P.C. Denver, CO 80203 Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Sternheim Attorneys for Chislaine Maxwell EFTA00015303 --- PAGE BREAK --- TABLE OF CONTENTS TABLE OF CONTENTS TABLE OF AUTHORITIES ii FACTUAL BACKGROU

idential information at the conclusion of the case, including Maxwell's deposition transcripts refused to do so although ordered to do so by Judge Sweet.' In its application to the governmen Not only did the government misunderstand how the Protective Order worked, but its argument also supports r

Avenue Denver, CO 80203 Phone: 303-831-7364 Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Bobbi C. Sternheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100 Attorneys for Ghislaine Maxwell EFTA000

be heard, but also by affirmatively misleading Chief Judge McMahon, 2 To this day, Judge Preska—who is presiding over the Giuffre action since Judge Sweet's passing and is addressing the Protective Order on a daily basis as the parties brief what material should be unsealed—apparently does not know th

D 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 Attorneys for Ghislaine Maxwell EFTA00028929 --- PAGE BREAK --- Table of Contents Table of Contents Fable of

rn District of New York to investigate and prosecute Epstein and Maxwell. Ex. J. Then, two months after the meeting with AUSA attorneys told Judge Sweet—who was presiding over defamation against Maxwell—that there was an 4 EFTA00028937 --- PAGE BREAK --- "ongoing criminal investigation" into Max

D 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 EFTA00029100 --- PAGE BREAK --- Table of Contents Table of Contents Fable of Authorities ii Table of Exhibit

rn District of New York to investigate and prosecute Epstein and Maxwell. Ex. J. Then, two months after the meeting with AUSA attorneys told Judge Sweet—who was presiding over defamation against Maxwell—that there was an 4 EFTA00029108 --- PAGE BREAK --- "ongoing criminal investigation" into Max