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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
D SIX Jeffrey 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 St
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
ISMISS COUNTS 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
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
E AND SIX Jeffrey 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 Fl
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
the government's Subpoena to Boies Schiller and to Dismiss Counts Five and Six upon the following: U.S. U.S. Attorne 's Office, SDNY s/ Christian R. Everdell 15 EFTA00097350
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
Suppress All Evidence Obtained from the government's Subpoena to Boies Schiller and to Dismiss Counts Five and Six upon the following: s/ Christian R. Everdell 15 EFTA00097668
Entities connected to both Schiller and R. Everdell

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Michael Cohen
PERSONJeffrey Pagliuca
PERSONCohen & Gresser LLP
ORGANIZATION
David Boies
PERSON
United States
LOCATIONSecond Circuit
ORGANIZATION
Julie K. Brown
PERSONthe Southern District
LOCATION
Stephen Hawking
PERSONMark S. Cohen
PERSONMORGAN & FOREMAN
ORGANIZATION
Prince Andrew
PERSON
Denver
LOCATION
Southern District of New York
ORGANIZATIONSouthern District
LOCATION
Bradley Edwards
PERSON
United Kingdom
LOCATION
Colorado
LOCATION