Epstein Secrets

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 . Stemheim Attorneys for Chislaine Maxwell EFTA00029816 --- PAGE BREAK --- TABLE OF CONTENTS TABLE OF

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

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

us with any questions. Your consideration is greatly appreciated. Respectfully submitted, Is/ Christian R. Everdell Christian R. Everdell COHEN & GRESSER LLP MEN cc: All counsel of record (via email) I For documents that the government has designated as "Confidential," we have preliminarily indicated t

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.

029131 --- PAGE BREAK --- Respectfully submitted, s/ Jeffrey S. Pagliuca Jeffrey S. Pagliuca Laura A. Menninger Christian R. Everdell COHEN & GRESSER LLP EMAN P.C. Bobbi C. Stemheim Attorneys for Ghislaine Maxwell 28 EFTA00029132 --- PAGE BREAK --- Certificate of Service I hereby certify that