Epstein Secrets

EMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION FOR A SEVERANCE OF AND SEPARATE TRIAL ON COUNTS FIVE AND SIX OF THE SUPERSEDING INDICTMENT Jeffrey S. Pagliuca 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

AND SIX OF THE SUPERSEDING INDICTMENT Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C

or transaction" as the Mann Act Counts and cannot be joined. Fed. R. Crim. P. 8(a); see Halper, 590 F.2d at 430 (temporally and factually distinct Medicaid fraud and tax evasion offenses were not based on same transaction, nor were they "of the same or similar character" simply because both involved att

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. Can yo

upport her argument, because they involve wholly unrelated events. See, e.g., United States v. Halper, 590 F.2d 422, 431 (2d Cir. 1978) (severing a Medicaid fraud indictment from a tax evasion indictment where the only similarly was the defendant's manipulation of people he had employed—different 53 Whi

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. Can yo

upport her argument, because they involve wholly unrelated events. See, e.g., United States v. Halper, 590 F.2d 422, 431 (2d Cir. 1978) (severing a Medicaid fraud indictment from a tax evasion indictment where the only similarly was the defendant's manipulation of people he had employed—different 53 Whi

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. Can yo

upport her argument, because they involve wholly unrelated events. See, e.g., United States v. Halper, 590 F.2d 422, 431 (2d Cir. 1978) (severing a Medicaid fraud indictment from a tax evasion indictment where the only similarly was the defendant's manipulation of people he had employed—different 53 Whi

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. 123 EFTA

upport her argument, because they involve wholly unrelated events. See, e.g., United States v. Halper, 590 F.2d 422, 431 (2d Cir. 1978) (severing a Medicaid fraud indictment from a tax evasion indictment where the only similarly was the defendant's manipulation of people he had employed—different in eac

o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. Can yo

upport her argument, because they involve wholly unrelated events. See, e.g., United States v. Halper, 590 F.2d 422, 431 (2d Cir. 1978) (severing a Medicaid fraud indictment from a tax evasion indictment where the only similarly was the defendant's manipulation of people he had employed—different While