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UNDER THE DUE PROCESS CLAUSE TO SUPPRESS ALL EVIDENCE OBTAINED FROM THE GOVERNMENT'S SUBPOENA TO BOLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Christian R. Everdell COHEN & GRESSER LLP 800 Third Ave
ER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C
USA back to court for one reason. "I'll be very up-front with you," she said. Mot. Ex. E, p 2. 14 EFTA00077589 I want to make sure I'm not in a Chemical Battk[15] kind of situation, so I would like to know about contacts between the United States Attorney's Office and the Boies Schiller firm prior t
o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. 123 EFTA
ranscript, no contact women_ the ant at nallavernment ongation. (Def. Mot. 3 at 1). Instead, ChiefJudgeltNahon's cAlgaismore specific: rearing Chemical figgrand desire to avoid "a Chemical Bank kind OREM5n," Chief Judge Mahon asked about cont between the two parties "prior to the issuance of the sub
o use them for purposes of sexual massages? MR. PAGLIUCA: Objection to the form and foundation. A. Can yo
s investigation and the issuance of the subpoena. Additionally, and in light of the Government's prior arguments to Chief Judge McMahon relating to Chemical Bank,40 the Government attempted to address the misconduct at issue in that case: namely the production of confidential documents without seeking m
Entities connected to both Jeffrey Pagliuca and Chemical

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSON
Michael Cohen
PERSON
Denver
LOCATION
Prince Andrew
PERSON
Colorado
LOCATION
David Boies
PERSONSigrid McCawley
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
Bradley Edwards
PERSONthe Southern District
LOCATION
Audrey Strauss
PERSON
Bronx
LOCATIONSecond Circuit
ORGANIZATION
Julie K. Brown
PERSON
Stephen Hawking
PERSON
Virginia Giuffre
PERSONMaria Farmer
PERSONLeon Black
PERSON