Epstein Secrets

uld unfairly damage their reputations' Jeffrey S. Pagliuca, an attorney involved in the litigation, "said th

d a judge not to release his name or the names of others accused in the documents of wrongdoing, arguing it could unfairly damage their reputations' Jeffrey S. Pagliuca, an attorney involved in the litigation, "said the people are named in 29 depositions, voluminous investigatory records and an 'address book' that i

n?" Cohen argues, "As I have long suggested, John Brennan and James Clapper, head of the CIA and Office of

elligence agencies, prompted, it seems clear, by US ones, seek to undermine Trump's presidential campaign?" Cohen argues, "As I have long suggested, John Brennan and James Clapper, head of the CIA and Office of National Intelligence under Obama respectively, are the more likely culprits. The FBI is no longer

g generated by CM/ECF. Laura A. Menninger, Esq. Jeffrey S. Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Av

by CM/ECF. Laura A. Menninger, Esq. Jeffrey S. Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 1

team. Her desire is, of course, no basis to deny the pending pro hac vice motion. See Richardson-Merrell, Inc. v. Koller, 472 U.S. 424, 441 (1985) (Brennan, J., concurring) ("the tactical use of attorney-misconduct disqualification motions is a deeply disturbing phenomenon in modern civil litigation. W

Bloomberg, "The government's failure to provide the evidence makes it impossible for Maxwell to prepare her defense, the British socialite's lawyer Jeffrey Pagliuca said Friday in a letter to U.S. District Judge Alison Nathan." As an illustration, the indictment does not provide exact "dates for when Maxwell co

ration, the indictment does not provide exact "dates for when Maxwell committed the alleged crimes, only saying they occurred between 1994 and 1997, Pagliuca said." He wrote, "Neither the indictment nor the discovery inform Ms. Maxwell about critical information necessary to prepare her defense." Teenag

Reid said that on CBS' Face The Nation, Margaret Brennan pressed National Security Advisor O'Brien, "who

Bloomberg, "The government's failure to provide the evidence makes it impossible for Maxwell to prepare her defense, the British socialite's lawyer Jeffrey Pagliuca said Friday in a letter to U.S. District Judge Alison Nathan." As an illustration, the indictment does not provide exact "dates for when Maxwell com

ation, the indictment does not provide exact "dates for when Maxwell committed the alleged crimes, only saying they occurred between 1994 and 1997, Pagliuca said." He wrote, "Neither the indictment nor the discovery inform Ms. Maxwell about critical information necessary to prepare her defense." Teenag

Reid said that on CBS' Face The Nation, Margaret Brennan pressed National Security Advisor O'Brien, "who

CT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) GIIISLAINE MAXWE 'S MOTION FOR A NEW TRIAL Jeffrey S. Pagliuca Laura A. Menninger HADDON. M R AN & FOREMAN P.C. Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim

AINE MAXWE 'S MOTION FOR A NEW TRIAL Jeffrey S. Pagliuca Laura A. Menninger HADDON. M R AN & FOREMAN P.C

onal right to a fair and impartial jury have been violated. McDonough, 464 U.S. at 553-56; id. at 556-57 (Blackmun, J., concurring); id. at 557-59 (Brennan, J., concurring in judgment). So long as a truthful answer would have subjected the juror to a challenge for cause based on bias, an inadvertent fal

ON TO THE GOVERNMENT'S MOTION FOR DETENTION Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca (pro hoc vice admission pending) Laura A. Menninger HADDON, MORGAN & FORMAN P.C. 150 East 10th Avenue Denver Colorado 80203 Phone: Attorneys f

rd Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca (pro hoc vice admission pending) Laura A. Menni

. 1987). For this reason, a judge may deny a defendant bail "only for the strongest of reasons." Hung v. United States, 439 U.S. 1326, 1329 (1978) (Brennan, 25 EFTA00093070 Case 21-770. Document 17-1, 04/01/2021, 3068296, Page28 of 31 J.). The Constitution's "prohibitions on the deprivation of liber

NDMENT, MARTINDELL, AND THE FIFTH AMENDMENT TO SUPPRE ALL EVIDENCE OBTAINED FROM THE GOVERNMENT'S SUBPOENA T AND TO DISMISS COUNTS FIVE AND SIX 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 A

he Fourth Amendment protects `effects' as well as people from unreasonable searches and seizures." United States v. Place, 462 U.S. 696, 716 (1983) (Brennan, J. concurring). It thus "protects two different interests of the citizen—the interest in retaining possession of property and the interest in main