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addresses receive invitations to the video conference. • • • • • Best, From: Christian Everdell • Sent: Thursday, July 2, 20201:14 PM To: 'Jeff Pagliuca' Cc: Subject: RE: SDNY indictment ; Mark S. Cohen < >; Laura Menninger Mark and I would also like to listen in. As we mentioned, we will not be a
Subject: RE: SDNY indictment Please add Jeff ); Christian Everdell; Mark S. Cohen; Laura Menninger and to the list. Thank you, EFTA00084307 Jeffrey S. Pagliuca Haddon, Morgan and Foreman, P.C. mation that is confidential or legally privileged. If you are not the intended recipient, or a person responsible
• Sent: Thursday, July 2, 20201:14 PM To: 'Jeff Pagliuca' Cc: Subject: RE: SDNY indictment ; Mark S. Co
Subject: SDNY indictment Chris, Mark, and Jeff, We are writing to inform you that the FBI arrested your client, Ghislaine Maxwell, this morning in Bradford, New Hampshire. I have attached the indictment and arrest warrant, which we are providing to you as a courtesy while we seek the formal unsealing o
epasinEaft,40=230,4ffientDdlignitiaffiatalelitheffffefilagtegtataf 8 The Honorable Alison J. Nathan July 21, 2020 Page 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,
ederal prosecutor's office in the Southern District of New York. "In some cases, Maxwell participated in the abuse herself." A lawyer for Maxwell, Jeff Pagliuca, did not immediately respond to messages seeking comment. David Boies, who along with Sigrid McCawley represents a dozen of Epstein's accusers, sa
2020 Page 7 Respectfully Submitted, Jeffrey S. Pagliuca cc: U.S. Attorney's Office for the Southern Dis
orneys for several of Epstein's alleged victims struggled to locate her in order to serve their lawsuits. She was ultimately arrested by the FBI in Bradford. New Hampshire, where prosecutors say she was living at a 156-acre property, nicknamed "Tucked Away? Prosecutors are now arguing that Maxwell pose
ederal prosecutor's office in the Southern District of New York. "In some cases, Maxwell participated in the abuse herself." A lawyer for Maxwell, Jeff Pagliuca, did not immediately respond to messages seeking comment. David Boies, who along with Sigrid McCawley represents a dozen of Epstein's accusers, sa
on' by law enforcement, Cohen claimed her phone had been hacked and she had to preserve the phone as evidence. MAXWELL'S LEGAL TEAM: Pictured l-r: Jeffrey S. Pagliuca,Christian R Everdell, Laura A. Menninger and Mark Cohen. In their filings to the court Maxwell's lawyers had argued that she is at increased risk o
the abuse herself." A lawyer for Maxwell, Jeff Pagliuca, did not immediately respond to messages seeking
orneys for several of Epstein's alleged victims struggled to locate her in order to serve their lawsuits. She was ultimately arrested by the FBI in Bradford. New Hampshire, where prosecutors say she was living at a 156-acre property, nicknamed "Tucked Away? Prosecutors are now arguing that Maxwell pose
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
ttorney Audrey Strauss, the head of New York's FBI office and lawyers for accusers of British socialite Ghislaine Maxwell after her July 2 arrest in Bradford, New Hampshire. He said the EFTA00135641 comments show that an order is necessary to prevent 'prejudicial pretrial publicity by the government, i
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
torney Audrey Strauss, the head of New York's FBI office and lawyers for accusers of British socialite Ghislaine Maxwell after her July 2 arrest in Bradford, New Hampshire. He said the comments show that an order is necessary to prevent `prejudicial pretrial publicity by the government, its agents, and l
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
ttorney Audrey Strauss, the head of New York's FBI office and lawyers for accusers of British socialite Ghislaine Maxwell after her July 2 arrest in Bradford, New Hampshire. He said the comments show that an order is necessary to prevent 'prejudicial pretrial publicity by the government, its agents, and
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
941 F.2d 114 (2d Cir. 1991) 4 United States v. Botti, No. 3:08-cr-00230 (CSH), 2009 WL 3157582 (S.D.N.Y. Sept. 25, 2009) 4, 9 United States v. Bradford, 487 F. Supp. 1093 (D. Conn. 1980) 5 United States v. Brown, No. 07-0296-1, 2008 WL 161146 (E.D. Pa. Jan. 16, 2008) 4, 7 United States v. Burke,
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
fendant appears to have been hiding on a 156-acre property acquired in an all-cash purchase in December 2019 (through a carefully anonymized LLC) in Bradford, New Hampshire, an area to which she has no other known connections. The defendant appears to have no ties that would motivate her to remain in the
on' by law enforcement, Cohen claimed her phone had been hacked and she had to preserve the phone as evidence. MAXWELL'S LEGAL TEAM: Pictured l-r: Jeffrey S. Pagliuca,Christian R Everdell, Laura A. Menninger and Mark Cohen. In their filings to the court Maxwell's lawyers had argued that she is at increased risk o
. MAXWELL'S LEGAL TEAM: Pictured l-r: Jeffrey S. Pagliuca,Christian R Everdell, Laura A. Menninger and Mar
ng under an assumed identity. There really can be no question that she can live in hiding.' She revealed when Maxwell bought her $1 million home in Bradford, New Hampshire last December, she toured the property with a real estate agent using an alias. said: 'The real estate agent told the FBI agent the
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
ttorney Audrey Strauss, the head of New York's FBI office and lawyers for accusers of British socialite Ghislaine Maxwell after her July 2 arrest in Bradford, New Hampshire. He said the comments show that an order is necessary to prevent `prejudicial pretrial publicity by the government, its agents, and
Entities connected to both Jeffrey Pagliuca and Bradford

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSONLaura Menninger
PERSON
Michael Cohen
PERSON
Denver
LOCATION
Prince Andrew
PERSONSouthern District
LOCATION
Christian Everdell
PERSONCohen & Gresser LLP
ORGANIZATION
Colorado
LOCATIONBates
PERSON
Department of Justice
ORGANIZATION
Alison J. Nathan
PERSON
Foreman
PERSON
David Boies
PERSON
United States
LOCATIONMark S. Cohen
PERSONSigrid McCawley
PERSONthe Southern District
LOCATION
Bradley Edwards
PERSON