Epstein Secrets

me-Barred 3. Reply Memorandum in Support of Motion Under the Due Process Clause to Suppress All Evidence Obtained from the Government's Subpoena to Boies Schiller and to Dismiss Counts Five and Six 4. Reply Memorandum in Support of Motion to Dismiss Counts Five and Six of the Superseding Indictment Because t

GG COHEN & GRESSER LLP Mark S. Cohen Christian R Fverdell March 15, 2021 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: On behalf

le Alison J. Nathan United States District Court Southern District of New York Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: On behalf of our client, Ghislaine Maxwell, we will be filing the following reply memoranda with accompanying exhibits: I. Reply Memorandum in Su

H A D D O N MORGAN FOREMAN March 9, 2021 The Hon. Alison J. Nathan United States District Court Judge Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, r c Laura A. M

Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Objection to Proposed Redactions of Government's Omnibus Response & Exhibit 5 Dear Judge Nathan: On behalf of defendant Ghislaine Maxwell, we respectfully oppose certain of the redactions proposed by the government to their Omnibus Memorandum

rocedure are being released to the public under the= unsealing process, without objection from the government. The name of the subpoena recipient (Boies Schiller) and the names of Chief Judge McMahon and Magistrate Judge Netburn (who issued their rulings nearly two years ago) certainly cannot alone compromis

Wednesday, June 16, 2021 11:58 AM To: (USANYS) < Cc: (USANYS) Subject: RE: Question re A1N/Maxwell Suppression Hearing Pottinger was a lawyer at Boies Schiller who represented the plaintiff in the civil action. The two letters we submitted in connection with our All Writs Application are attached. From:

the McMahon proceedings and her opinion (Ex D, E, G); (3) our brief (see pp 59-115); and (4) the exhibits we attached to our motion (Ex 4-7). Judge Nathan has said that she will resolve the suppression motions "at a later time" ahead of trial. Thanks very much. From: (USANYS) Sent: Tuesday, June 15,

r potential witnesses that going forward it will not hesitate to take appropriate action in the face of violations of any relevant rules." Id. judge Nathan said she would ensure "strict compliance" with the rules and "ensure that the Defendant's right to a fair trial will be safeguarded." Id. On July

1, 2020, the Court said it was "troubled" to learn that plaintiff's successor counsel, Cooper & Kirk, had received from plaintiff's former counsel, Boies Schiller Flexner, various discovery materials that were subject to the Protective Order. Doc.1071 at 4. The Court rejected Cooper & Kirk's suggestion that i

all_writs_act_application,_15_Civ_7433_(RWS).pdf; 2019-02- 28, JEJetter_re_all_writs_act_application,_17_Civ_0616_(SN).pdf Pottinger was a lawyer at Boies Schiller who represented the plaintiff in the civil action. The two letters we submitted in connection with our All Writs Application are attached. From:

the McMahon proceedings and her opinion (Ex D, E, G); (3) our brief (see pp 59-115); and (4) the exhibits we attached to our motion (Ex 4-7). Judge Nathan has said that she will resolve the suppression motions "at a later time" ahead of trial. Thanks very much. From: (USANYS) < Sent: Tuesday, June 1