Epstein Secrets

tion that it properly was a recipient of the material: [W]hatever Cooper & Kirk's intentions in requesting and obtaining the Maxwell materials from Boies Schiller, the Maxwell Protective Order explicitly provides that (1) discovery materials designated CONFIDENTIAL cannot be EFTA00075057 Caest 131-63.403481

e 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, Morgan & Foreman, P.C. EFTA00075071 Cagesle120o140ZaUX.PertDo&Aflt."1016ZO. PEIR603824/20e1a4e205f 2 EXHIBIT B EFTA

TO BOLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Ghislaine Maxwell EFTA00028929 --- PAGE BREAK --- Table of Contents Table of

18 IV. The Remedy for the Government's Misconduct 20 A. Pursuant to its Inherent Power, this Court Should Suppress the Evidence Obtained from Boies Schiller and Dismiss Counts Five and Six, which are the Fruits of that Evidence. 20 B. At a Minimum, this Court Should Order a Hearing at which Maxwell Ma

ew all of this and still denied that Boies Schiller had any role in fomenting the investigation and claimed that there had been no contacts between Boies Schiller and his office before November 2018, when he claimed the investigation first began. None of these statements by AUSA to Judge McMahon were true.

Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303-831-7364 Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New

o prosecutors for the purpose of fomenting an investigation. But I am not faced with that situation. Nothing in this record suggests to me that or Boies Schiller had anything to do with the Government's decision to convene a grand jury to look into the matters that were the subject of the Action. On the con

slaine Maxwell, through counsel, respectfully moves to suppress under the due process clause all evidence obtained from the government's subpoena to Boies Schiller and to dismiss Counts Five and Six. Dated: January 25, 2021 New York, New York EFTA00023047 --- PAGE BREAK --- Respectfully submitted, s/ Jef

y S. Pagliuca Jeffrey S. Pagliuca Laura A. Menninger HADDON. MORGAN & FOREMAN P.C. Denver CO 80203 Phone: Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP New York NY 10022 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim New York NY 10011 Phone Attorneys for Ghislaine Maxwell 1 EFTA00

LLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON MORGAN & FOREMAN P.C. Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Chislaine Maxwell EFTA00029077 --- PAGE BREAK --- TABLE OF CONTENTS TABLE OF

oena. INTRODUCTION AND SUMMARY OF THE ARGUMENT Counts Five and Six allege that Maxwell committed perjury during two civil depositions conducted by Boies Schiller in a defamation action it filed against Maxwell on behalf of one of the firm's clients. v. Marvell, Case No. 15-cv-7433 (LAP) (S.D.N.Y). A Protecti

TO BOLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Sternheim Attorneys for Ghislaine Maxwell EFTA00029100 --- PAGE BREAK --- Table of Contents Table of Contents Fable of Authorities

ew all of this and still denied that Boies Schiller had any role in fomenting the investigation and claimed that there had been no contacts between Boies Schiller and his office before November 2018, when he claimed the investigation first began. None of these statements by AUSA to Judge McMahon were true.

An Identical Gambit By The Government 10 ARGUMENT 11 A. Pursuant To Its Inherent Power, This Court Should Suppress The Evidence Obtained From Boies Schiller, And Dismiss Counts Five And Six, Which Are The Fruits Of That Evidence 11 I. The role of protective orders in civil litigation 11 2. The go

ully submitted, s/ Jeffrey S. Pagliuca Jeffrey S. Pagliuca Laura A. Menninger HADDON MORGAN & FOREMAN P.C. Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Chislaine Maxwell 17 EFTA00029837 --- PAGE BREAK --- Certificate of Service