Epstein Secrets

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

mob, Ms. Maxwell is presumed innocent and is entitled to defend herself. Accordingly, Ms. Maxwell moves this Court for her immediate release. Fed. R. App. P. 9; 18 U.S.C. §§3142 and 3145. * * * 3 EFTA00093048 Case 21-770, Document 17-1. 04/01/2021. 3068296. Page6 of 31 ISSUES PRESENTED 1. Whe

4 K7N9GIUD 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 150. Declaration of Mister -- how does he say it, Mr. Pagliuca? Say it again. MS. MENNINGER: Pagliuca. THE COURT: Mr. Pagliuca in opposition to the motion to compel. Unseal. 150-1. Additional pages from Ms. M

ocument 40, 08/20/2020, 2913550, Page49 of 74 Certificate of Compliance with Rule 32(A) This brief complies with the type-volume limitation of Fed. R. App. P. 32(a)(7)(B). It contains 9,112 words, excluding the parts of the brief exempted by Fed. R. App. P. 32(a)(7)(B)(III). This brief complies with

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

oduced to the defense on or about August 12, 2020. As a result, Maxwell could have sought review ofr Nari ll order in the Second Circuit. See Fed. R. App. P. 4(a)(6). Maxwell asks this Court to second-guess a coequal district court's decision to modify a protective order. Putting aside the question of

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

e defense on or about August 12, 2020. As a result, Maxwell could have sought review of Chief Judge McMahon's order in the Second Circuit. See Fed. R. App. P. 4(a)(6). Maxwell asks this Court to second-guess a coequal district court's decision to modify a protective order. Putting aside the question of

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

e defense on or about August 12, 2020. As a result, Maxwell could have sought review of Chief Judge McMahon's order in the Second Circuit. See Fed. R. App. P. 4(a)(6). Maxwell asks this Court to second-guess a coequal district court's decision to modify a protective order. Putting aside the question of

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

were produced to the defense on or about August 12, 2020. As a result, Maxwell could have sought review of order in the Second Circuit. See Fed. R. App. P. 4(a)(6). Maxwell asks this Court to second-guess a coequal district court's decision to modify a protective order. Putting aside the question of

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

e defense on or about August 12, 2020. As a result, Maxwell could have sought review of Chief Judge McMahon's order in the Second Circuit. See Fed. R. App. P. 4(a)(6). Maxwell asks this Court to second-guess a coequal district court's decision to modify a protective order. Putting aside the question of