Epstein Secrets

20, denying Ms. Maxwell's motion to reconsider. Dated: July 29, 2020. Respectfully submitted, s/ Laura A. Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) Ty Gee (pro hac vice) HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Ghislaine Maxwell 1 EFTA00076389 CasastrabiAZI71432)IaAini

Sorry. No. 6 Thanks very much. 7 MR. CASSELL: Thank you, your Honor. 8 THE COURT: Anything from the defense. 9 MR. PAGLIUCA: Yes, your Honor. Jeff Pagliuca on 10 behalf of Ms. Maxwell. 11 Your Honor, I have never opposed a pro hac motion in 12 my 34 years of practice, so this is a first for me. But

23 24 25 Case 20-2413, Document 44, 08/20/2020, 2913556, Page67 of 78 K7N9GIUD App.-0841 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

Cr. 330 (AJN) (the "Criminal Action"). The information implicates Ms. Maxwell's right to due process and fairness in this civil action and affects the Second Circuit's review of the Court's unsealing order of July 23, 2020. Additionally, the information implicates her rights as a criminal defendant guaranteed unde

MENTAL PRETRIAL MOTIONS RELATING TO THE S2 SUPERSEDING INDICTMENT Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim

800 Third Avenue New York, NY 10022 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C

ernment offers only one argument for why it should be permitted to prosecute Ms. Maxwell for these offenses. Relying on the Court's prior ruling and the Second Circuit's decision in United States v. Annabi, 771 F.2d 670 (2d Cir. 1985) (per curiam), the government asserts that the NPA does not bind the U.S. Attorney'

ing on her motions to suppress and that it rule on the merits of her arguments before the trial on the non-perjury counts. Respecifidly submitted, Jeffrey S. Pagliuca CC: Counsel of Record EFTA00105931

jury counts. Respecifidly submitted, Jeffrey S. Pagliuca CC: Counsel of Record EFTA00105931

. at I. That's because Ms. Maxwell's motions to suppress allege violations of the due process clause, the Fourth Amendment, the Fifth Amendment, and the Second Circuit's decision in Manindell v. International Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979). If this Court agrees with Ms. Maxwell's arguments, not only

SLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Reply In Support Of Iler Objections to tnsealinu Sealed Materials Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue EFTA00074964 Ca_QatIgt24743tictoWneDbtOrfiefiVIMOXIle?BOWERKVaffizte12401 22 Intr

Sealed Materials Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 Ea

re "unjustified obstacles" or that the public will never have access to these documents -- reflect unjustified criticisms of the Protocol itself and the Second Circuit's decision in Brown, both of which fairly outline the legal process for parties and Non-Parties alike to be heard with respect to unsealing. Notably,

s. Maxwell's Objections to Unsealing Docket Entries 143. 173. and 199 and to Unsealing Docket Entries 164 and 230 at This Time. Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 EFTA00075004 CageaUlg0caAIDer0dthhilfii igl5V2Pil&iA6/2bagctaci

230 at This Time. Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 Ea

19) (emphasis supplied; footnote omitted; quoting United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995) ("Amodeo r')). Amodeo I, the inception of the Second Circuit's principle that a file stamp is not a judicial-document talisman, is instructive. There an appointed Court Officer tasked parties; DE 204-1 referenc

ame reason. Pages 20 to 23. Testimony from or about the Does. The shaded material shall remain sealed except for Detective 340. Declaration of Mr. Pagliuca. Unseal and redact only the names and identifying information of the nonparties. I will note Detective is in there and Ms. Maxwell's depositions

Messages involving the defendant. Portions of this document were redacted and released by the Second Circuit. So whatever happened with respect to the Second Circuit's release, we will abide by its ruling. 339. Response in opposition to the motion to compel. Unseal and redact the names, identifying information, a

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

w, and should be denied. 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks Maxwell argues that the Government "circumvented" the Second Circuit's decision in Martindell and "violated Maxwell's rights," which requires suppression of the evidence the Government obtained from the subpoena. (Def.

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

w, and should be denied. 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks Maxwell argues that the Government "circumvented" the Second Circuit's decision in Martindell and "violated Maxwell's rights," which requires suppression of the evidence the Government obtained from the subpoena. (Def.

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

w, and should be denied. 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks Maxwell argues that the Government "circumvented" the Second Circuit's decision in Martindell and "violated Maxwell's rights," which requires suppression of the evidence the Government obtained from the subpoena. (Def.

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

w, and should be denied. 1. Martindell Provides No Basis to Grant the Relief the Defendant Seeks Maxwell argues that the Government "circumvented" the Second Circuit's decision in Martindell and "violated Maxwell's rights," which requires suppression of the evidence the Government obtained from the subpoena. (Def.