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ES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x MS. MAXWELL'S MOTION FOR AN ORDER AUTHORIZING A SUBPOENA PURSUANT TO FED. R. CRIM. P 17(c)(3) Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi . Stemheim A
PURSUANT TO FED. R. CRIM. P 17(c)(3) Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C
defense. These rolling productions confirmed that the four Accusers referenced in the indictment applied for and received millions of dollars from the Epstein Victim Compensation Fund. Ms. Maxwell requests the Court's assistance in subpoenaing documents submitted by the Accusers and the witnesses for use at trial. The documents s
ISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) MS. MAXWELL'S MOTION FOR AN ORDER AUTHORIZING A SUBPOENA PURSUANT TO FED. R. CRIM. P 17(c)(3) Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver CO 80203 Phone: Christian R. Everdell COHEN & GRESSER LLP 800 Th
PURSUANT TO FED. R. CRIM. P 17(c)(3) Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C
defense. These rolling productions confirmed that the four Accusers referenced in the indictment applied for and received millions of dollars from the Epstein Victim Compensation Fund. Ms. Maxwell requests the Court's assistance in subpoenaing documents submitted by the Accusers and the witnesses for use at trial. The documents s
to address any questions regarding relevance and admissibility ex-parte should the Court need any additional information. Respectfully Submitted, Jeffrey S. Pagliuca CC: Counsel of Record (via ECF) EFTA00096517
Y 10007 Haddon, Morgan and Foreman. t.c Jeffrey PaglIuca 150 East 10th Avenue Denver. Colorado 80203 PH
cluding the truth. Request 9, The Journal Accuser-2 has been represented by BSF since approximately 2016. She sued Ms. Maxwell and participated in the Epstein Victim Compensation Fund. She claims to have kept a journal for a period in 1996 in which she described various events, including her interactions with Jeffrey Epstein. Sev
cluding the truth. Request 9, The Journal Accuser-2 has been represented by BSF since approximately 2016. She sued Ms. Maxwell and participated in the Epstein Victim Compensation Fund. She claims to have kept a journal for a period in 1996 in which she described various events, including her interactions with Jeffrey Epstein. Sev
Page: EFTA00014672 →ddress any questions regarding relevance and admissibility ex-parte should the Court need any additional information. Respectfully Submitted, g's Jeffrey S. Pagliuca CC: Counsel of Record (via ECF) EFTA00014678
Page: EFTA00014678 →Entities connected to both Jeffrey Pagliuca and the Epstein Victim Compensation Fund

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSON
Michael Cohen
PERSON
Denver
LOCATION
Prince Andrew
PERSONCohen & Gresser LLP
ORGANIZATIONBobbi C. Sternheim
PERSON
Colorado
LOCATION
David Boies
PERSONMORGAN & FOREMAN
ORGANIZATION
Brady
PERSON
Kentucky
LOCATION
Bagley
PERSONJack Scarola
PERSON
Cynthia Nixon
PERSONDarren Indyke
PERSONAccusers
ORGANIZATIONthe Second Circuit Court of Appeals
ORGANIZATION
Michael Barker
PERSONBilzerian
PERSON