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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
REMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 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 10011 Phone: Attorneys for Ghislaine Maxwell 28 EFTA00077603 C
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
. 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 10011 Phone: Attorneys for Ghislaine Maxwell EFTA00086658 TABLE
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
MISS 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 CONTENTS ii TABLE OF AUTHORI
Entities connected to both Schiller and Bobbi C. Stemheim

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
David Boies
PERSONJeffrey Pagliuca
PERSON
Michael Cohen
PERSON
Julie K. Brown
PERSON
Bradley Edwards
PERSONCohen & Gresser LLP
ORGANIZATIONthe Southern District
LOCATION
Stephen Hawking
PERSONJane Doe
PERSON
Prince Andrew
PERSONSecond Circuit
ORGANIZATION
United States
LOCATIONLoretta A. Preska
PERSONR. Everdell
PERSONColleen McMahon
PERSONMark S. Cohen
PERSONSigrid McCawley
PERSONLaura Menninger
PERSON