Epstein Secrets

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

I. Background On October 11, 2021, the government began producing 3500 material to the 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

The name, address, e-mail, and telephone number of the attorney representing (name of party) Ghislaine Maxwell , who requests this subpoena, are: Jeffrey S. Pagliuca, Haddon, Morgan & Foreman P.C., 150 East 10th Ave., Denver, Colorado 80203, 303.831.7364, [email protected] Notice to those who use this form to

l , who requests this subpoena, are: Jeffrey S. Pagliuca, Haddon, Morgan & Foreman P.C., 150 East 10th Ave

tted by each Accuser, not limited to Claim Forms and supporting submissions made by each Accuser; 2. Communications between the EVCP to each of the Accusers and/ or their Attorneys; 3. Copies of any payments to the Accusers and their Attorneys; 4. Any and All Releases executed by the Accusers. EFTA0004

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

I. Background On October 11, 2021, the government began producing 3500 material to the 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

The name, address, e-mail, and telephone number of the attorney representing (name of party) Ghislaine Maxwell , who requests this subpoena, are: Jeffrey S. Pagliuca. Haddon, Morgan & Foreman P.C., 150 East 10th Ave., Denver, Colorado 80203, Notice to those who use this form to request a subpoena Before requesti

l , who requests this subpoena, are: Jeffrey S. Pagliuca. Haddon, Morgan & Foreman P.C., 150 East 10th Ave

tted by each Accuser, not limited to Claim Forms and supporting submissions made by each Accuser; 2. Communications between the EVCP to each of the Accusers and/ or their Attorneys; 3. Copies of any payments to the Accusers and their Attorneys; 4. Any and All Releases executed by the Accusers. EFTA0010

The name, address, e-mail, and telephone number of the attorney representing (name of party) Ghislaine Maxwell , who requests this subpoena, are: Jeffrey S. Pagliuca. Haddon, Morgan & Foreman P.C., 150 East 10th Ave., Denver, Colorado 80203, Notice to those who use this form to request a subpoena Before requesti

l , who requests this subpoena, are: Jeffrey S. Pagliuca. Haddon, Morgan & Foreman P.C., 150 East 10th Ave

tted by each Accuser, not limited to Claim Forms and supporting submissions made by each Accuser; 2. Communications between the EVCP to each of the Accusers and/ or their Attorneys; 3. Copies of any payments to the Accusers and their Attorneys; 4. Any and All Releases executed by the Accusers. EFTA0009

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. Phone: Christian R. Everdell COHEN & DRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi C. St

AND SIX OF THE SUPERSEDING INDICTMENT Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C

d the truth or falsity of "obvious lies" about being sexually trafficked to famous people and her purported four years as a sex slave. None of the Accusers in the Indictment claim to have been sexually trafficked by Epstein or Ms. Maxwell to anyone, let alone any famous people. And the defamation case

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. Phone: Christian R. Everdell COHEN & DRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi C. St

AND SIX OF THE SUPERSEDING INDICTMENT Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C

d the truth or falsity of "obvious lies" about being sexually trafficked to famous people and her purported four years as a sex slave. None of the Accusers in the Indictment claim to have been sexually trafficked by Epstein or Ms. Maxwell to anyone, let alone any famous people. And the defamation case