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epasinEaft,40=230,4ffientDdlignitiaffiatalelitheffffefilagtegtataf 8 The Honorable Alison J. Nathan July 21, 2020 Page 7 Respectfully Submitted, Jeffrey S. Pagliuca cc: U.S. Attorney's Office for the Southern District of New York Mark Cohen Christian Everdell Cohen & Gresser LLP Laura A. Menninger Haddon,
ederal prosecutor's office in the Southern District of New York. "In some cases, Maxwell participated in the abuse herself." A lawyer for Maxwell, Jeff Pagliuca, did not immediately respond to messages seeking comment. David Boies, who along with Sigrid McCawley represents a dozen of Epstein's accusers, sa
2020 Page 7 Respectfully Submitted, Jeffrey S. Pagliuca cc: U.S. Attorney's Office for the Southern Dis
and sister of the Hollywood actress, Catherine Oxenberg - who rescued her eldest daughter India, now 28, from the Nxivm sex cult run by its leader, Keith Raniere, after an 18 month battle. India was among the women he recruited under the guise of offering them self-help courses. Her actress mother pulled her
ederal prosecutor's office in the Southern District of New York. "In some cases, Maxwell participated in the abuse herself." A lawyer for Maxwell, Jeff Pagliuca, did not immediately respond to messages seeking comment. David Boies, who along with Sigrid McCawley represents a dozen of Epstein's accusers, sa
on' by law enforcement, Cohen claimed her phone had been hacked and she had to preserve the phone as evidence. MAXWELL'S LEGAL TEAM: Pictured l-r: Jeffrey S. Pagliuca,Christian R Everdell, Laura A. Menninger and Mark Cohen. In their filings to the court Maxwell's lawyers had argued that she is at increased risk o
the abuse herself." A lawyer for Maxwell, Jeff Pagliuca, did not immediately respond to messages seeking
and sister of the Hollywood actress, Catherine Oxenberg - who rescued her eldest daughter India, now 28, from the Nxivm sex cult run by its leader, Keith Raniere, after an 18 month battle. India was among the women he recruited under the guise of offering them self-help courses. Her actress mother pulled her
Bloomberg, "The government's failure to provide the evidence makes it impossible for Maxwell to prepare her defense, the British socialite's lawyer Jeffrey Pagliuca said Friday in a letter to U.S. District Judge Alison Nathan." As an illustration, the indictment does not provide exact "dates for when Maxwell co
ration, the indictment does not provide exact "dates for when Maxwell committed the alleged crimes, only saying they occurred between 1994 and 1997, Pagliuca said." He wrote, "Neither the indictment nor the discovery inform Ms. Maxwell about critical information necessary to prepare her defense." Teenag
lletinintelligence.corn/c3330a4e79584b29b30fdd472I3e1225? pubid=fbi> (10/23, story 10, 2:54, Holt, I.82M) reported on an interview with NXIVM leader Keith Raniere to "Dateline" from jail "for the first time since his arrest." Correspondent Stephanie Gosk referred to NXIVM as "a shadowy self help organization
Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Ghislaine Maxwell EFTA0006571
tian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C
at exceeds the number of articles that mentioned such high-profile defendants as Harvey Weinstein, Bill Cosby, Joaquin "El Chapo" Guzman Loera, and Keith Raniere in the 90-day period following their arrests, combined. The media coverage has ruthlessly vilified her and prejudged her guilt, and has exposed her
Bloomberg, "The government's failure to provide the evidence makes it impossible for Maxwell to prepare her defense, the British socialite's lawyer Jeffrey Pagliuca said Friday in a letter to U.S. District Judge Alison Nathan." As an illustration, the indictment does not provide exact "dates for when Maxwell com
ation, the indictment does not provide exact "dates for when Maxwell committed the alleged crimes, only saying they occurred between 1994 and 1997, Pagliuca said." He wrote, "Neither the indictment nor the discovery inform Ms. Maxwell about critical information necessary to prepare her defense." Teenag
eader Speaks Ahead Of Sentencing. EFTA00148511 NBC Nightly NewsVi (10/23, story 10, 2:54, Holt, 1.82M) reported on an interview with NXIVM leader Keith Raniere to "Dateline" from jail "for the first time since his arrest." Correspondent Stephanie Gosk referred to NXIVM as "a shadowy self help organization d
Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Ghislaine Maxwell EFTA0015451
tian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C
at exceeds the number of articles that mentioned such high-profile defendants as Harvey Weinstein, Bill Cosby, Joaquin "El Chapo" Guzman Loera, and Keith Raniere in the 90-day period following their arrests, combined. The media coverage has ruthlessly vilified her and prejudged her guilt, and has exposed her
GHISLAINE MAXWELL IN SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Denver, CO 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim New York, NY 10011
ESSER LLP New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C
at exceeds the number of articles that mentioned such high-profile defendants as Harvey Weinstein, Bill Cosby, Joaquin "El Chapo" Guzman Loera, and Keith Raniere in the 90-day period following their arrests, combined. The media coverage has ruthlessly vilified her and prejudged her guilt, and has exposed her
rd Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C
IN SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemhe
at exceeds the number of articles that mentioned such high-profile defendants as Harvey Weinstein, Bill Cosby, Joaquin "El Chapo" Guzman Loera, and Keith Raniere in the 90-day period following their arrests, combined. The media coverage has ruthlessly vilified her and prejudged her guilt, and has exposed her
Entities connected to both Jeffrey Pagliuca and Keith Raniere

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSON
Michael Cohen
PERSON
Denver
LOCATION
Prince Andrew
PERSONCohen & Gresser LLP
ORGANIZATIONBates
PERSONMark S. Cohen
PERSON
David Boies
PERSON
Department of Justice
ORGANIZATIONSigrid McCawley
PERSON
United States
LOCATION
Bradley Edwards
PERSONMark Cohen
PERSONthe Southern District
LOCATIONSecond Circuit
ORGANIZATION
Audrey Strauss
PERSON
Stephen Hawking
PERSON
Virginia Giuffre
PERSON
Julie K. Brown
PERSON