Epstein Secrets

n this in more detail. Maxwell Pre-Trial Mot. Nos. 4 8c 5. But the point is this: The defamation case should have been extremely narrow, but Boies Schiller transformed it into something much broader—a proxy prosecution of Epstein and Maxwell for allegedly trafficking and abusing Giuffre, which then comp

y S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303-831-7364 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

t the Government's investigation. Moreover, the Assistant United States Attorney has represented to this Court that he has no idea what is in Boies Schiller's files, and that for all he knows every witness who was deposed stood on his/her Fifth Amendment rights and refused to answer questions. Id. at 21

FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Atto

aw firm had provided that information well before the investigation began. The government did indeed have previous contact with the firm. And Boies Schiller was instrumental in fomenting the Maxwell prosecution. The record is surpassingly clear: But for the government's misrepresentation, witting or not

ffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denverile. Phone: Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York NY 1001

n this in more detail. Maxwell Pre-Trial Mot. Nos. 4 8c 5. But the point is this: The defamation case should have been extremely narrow, but Boies Schiller transformed it into something much broader—a proxy prosecution of Epstein and Maxwell for allegedly trafficking and abusing which then compelled Ma

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 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Phone: Attorneys for Ghislaine Maxwell EFTA00097331 TABLE OF CONTENTS TABLE OF CON

n this in more detail. Maxwell Pre-Trial Mot. Nos. 4 8c 5. But the point is this: The defamation case should have been extremely narrow, but Boies Schiller transformed it into something much broader—a proxy prosecution of Epstein and Maxwell for allegedly trafficking and abusing which then compelled Ma

OM THE GOVERNMENT'S SUBPOENA TO BOLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Mennin • er Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Sternheim Law Offices of Bobbi C. Stemheim Attorneys for Ghislaine Maxwell EFTA00097649 TABLE OF CONTENTS TABLE OF CONTENTS ii TABL

fight with Epstein's alleged victims long before her recent arrest. "(Maxwell] has been using this Court as a sword and a shield for many years." Schiller wrote in a filing earlier this year, "and she, Jeffrey Epstein, and their other co-conspirators have attempted to thwart their victims from obtaini

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

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

1 FACTUAL BACKGROUND 2 A. The Protective Order in v. Maxwell 2 B. Maxwell's April and July 2016 depositions 4 C. The Settlement And Boies Schiller's Refusal To Comply With The Protective Order 6 D. The Government's False Statements To Judge McMahon 6 E. Judge Netburn Separately Rejects An

law firm had provided that information well before the investigation began. The government did indeed have previous contact with the firm. And Pomp Schiller was instrumental in fomenting the Maxwell prosecution. The record is surpassingly clear: But for the government's misrepresentation, witting or not

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

McMahon that the prosecutors had no idea what was in Boies Schiller's file. Indeed, he insisted, there had been no contact whatsoever between Boies Schiller and United States Attorney's Office before the government commenced its investigation. Nor, said the prosecutor, did Boies Schiller have any role in

aw firm had provided that information well before the investigation began. The government did indeed have previous contact with the firm. And Boies Schiller was instrumental in fomenting the Maxwell prosecution. The record is surpassingly clear: But for the government's misrepresentation, witting or not

1 FACTUAL BACKGROUND 2 A. The Protective Order in v. Maxwell 2 B. Maxwell's April and July 2016 depositions 4 C. The Settlement And Boies Schiller's Refusal To Comply With The Protective Order 6 D. The Government's False Statements To Judge McMahon 6 E. Judge Netburn Separately Rejects An

stify the government's secret, ex parte application . Ex. H, p 6. Judge Netburn also implicitly recognized what Judge McMahon never knew—that Boies Schiller was all too eager for the government to investigate and prosecute Maxwell: 6 Maxwell has not yet been provided discovery of whether Boies Schiller s

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

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

appeared before Judge McMahon barely four months later, however, he told her none of this, unequivocally and falsely disavowing any role by Boies Schiller in fomenting the investigation and denying any contacts between Boies Schiller and his office before November 2018. Even though AUSA had a "complet