Epstein Secrets

ilege Claims at Issue Defendant has withheld 99 pages of emails with communications involving various combinations of Brett Jaffe, Esq. ("Jaffe"), Mark Cohen, Esq. ("Cohen"), Philip Barden ("Barden"), Ross Gow ("Gown), Brian Basham ("Basham"), and The facts that follow summarize Defendant's assertions

3, 2014) (internal quotation marks omitted)). Moreover, at least one New York court has found that British privilege law is "apparently similar" to New York's. Aetna Cas. & Sur. Co. v. Certain Underwriters at Lloyd's London, 4 "Where there is no attorney involved in the communication ..., there can be no

uffre v. Maxwell, No. 15 CIV. 7433 (RWS), 2016 WL 831949, at *2 n.2 (S.D.N.Y. Feb. 29, 2016) ("Because New York has the most significant interest, New York law applies."). The potential litigation for which Defendant sought Barden's advice never came to frOition and no • pending issues in or relating

on J. Nathan July 21, 2020 Page 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.

a teenager during a bail hearing. The financier was found dead in his cell the following month. Ms is now suing Epstein's estate and Maxwell in the New York district court for damages. According to Ms testimony, detailed in the book, she was flown to the financier's vast Zorro Ranch after he offered to

Maxwell 'has never shown any remorse [andj tormented her survivors... She has associates across the globe, some of great means.' Maxwell's attorney Mark Cohen tried to argue his client was not a flight risk, claiming she has community ties and is 'part of a very large and close family'. He said: 'Our clie

rs and backed up by more than $3.75 million in property in the UK. Maxwell's legal team had argued she would be confined to a 'luxury hotel' in the New York area, surrender all her travel documents and be subject to GPS monitoring. But Judge Nathan ruled the British socialite was a significant flight ris

Maxwell 'has never shown any remorse [andj tormented her survivors... She has associates across the globe, some of great means.' Maxwell's attorney Mark Cohen tried to argue his client was not a flight risk, claiming she has community ties and is 'part of a very large and close family'. He said: 'Our clie

as a teenager during a bail hearing. The financier was found dead in his cell the following month. is now suing Epstein's estate and Maxwell in the New York district court for damages. According to Lestimony, detailed in the book, she was flown to the financier's vast Zorro Ranch after he offered to pa