Epstein Secrets

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

y S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th 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. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New

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

Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, 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 N

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

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 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Phone: Attorneys for Ghislaine Maxwell EFTA00097331 TABLE OF CONTENTS TABLE OF CON

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

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 Attorneys for Ghislaine Maxwell EFTA00097378 TABLE OF CONTENTS TABLE OF CONTENTS i TABL

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

OM THE GOVERNMENT'S SUBPOENA 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 TABL

n part, Ms. Maxwell needed information concerning any such investigation to assess "the impact on any 5th Amendment privilege." Id. at 2, 4-5. Judge Sweet denied that motion. The day before Ms. Maxwell's deposition, the Court ordered that "[a]ny materials that the plaintiff has with respect to any cri

e 7 Respectfully Submitted, Jeffrey S. Pagliuca cc: U.S. Attorney's Office for the Southern District of New York Mark Cohen Christian Everdell Cohen & Gresser LLP Laura A. Menninger Haddon, Morgan & Foreman, P.C. EFTA00075071 Cagesle120o140ZaUX.PertDo&Aflt."1016ZO. PEIR603824/20e1a4e205f 2 EXHIBIT B EFTA

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

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 EFTA00029100 --- PAGE BREAK --- Table of Contents Table of Contents Fable of Authorities

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