Epstein Secrets

tracking device" for purposes of Rule 41 where used to collect location data); In re Application, 2009 WL 159187, at *5 *6 (S.D.N.Y. Jan.13, 2009) (McMahon, J.) (same). 3 See 18 U.S.C. § 3121 (prohibiting use of pen register or trap and trace device without an order under the pen register statute); 312

eman," which I know from my review of court records is the name of a law firm that currently represents GHISLAINE MAXWELL in civil litigation (the "Haddon, Morgan, & Foreman Phone"). The most recent contact between Target Cellphone-1 and the Haddon, Morgan, & Foreman Phone occurred in or about February

inal) (quoting Mincey v. Arizona, 437 U.S. 385, 398 (1978)). Here, the government violated due process when it misrepresented and misled Chief Judge McMahon in an ex pane proceeding to circumvent the civil protective order, and it independently would violate due process for the government to be allowed

N April 22, 2021 The Hon. Alison J. Nathan United States District Court Judge Southern District of New York 40 Foley Square New York, NY 10007 Haddon, Morgan and Foreman, P.0 Jeffrey S. PagRoca Denver, Colorado 80203 wv.rw.nmnaw.com Re: United States v. Ghisiaine Maxwell, 20 Cr. 330 (AJN) Resp

tracking device" for purposes of Rule 41 where used to collect location data); In re Application, 2009 WL 159187, at *5 *6 (S.D.N.Y. Jan.13, 2009) (McMahon, J.) (same). 3 See 18 U.S.C. § 3121 (prohibiting use of pen register or trap and trace device without an order under the pen register statute); 312

eman," which I know from my review of court records is the name of a law firm that currently represents GHISLAINE MAXWELL in civil litigation (the "Haddon, Morgan, & Foreman Phone"). The most recent contact between Target Cellphone-1 and the Haddon, Morgan, & Foreman Phone occurred in or about February

tracking device" for purposes of Rule 41 where used to collect location data); In re Application, 2009 WL 159187, at *5 *6 (S.D.N.Y. Jan.13, 2009) (McMahon, J.) (same). 3 See 18 U.S.C. § 3121 (prohibiting use of pen register or trap and trace device without an order under the pen register statute); 312

eman," which I know from my review of court records is the name of a law firm that currently represents GHISLAINE MAXWELL in civil litigation (the "Haddon, Morgan, & Foreman Phone"). The most recent contact between Target Cellphone-1 and the Haddon, Morgan, & Foreman Phone occurred in or about February

tracking device" for purposes of Rule 41 where used to collect location data); In re Application, 2009 WL 159187, at *5 *6 (S.D.N.Y. Jan.13, 2009) (McMahon, J.) (same). 3 See 18 U.S.C. § 3121 (prohibiting use of pen register or trap and trace device without an order under the pen register statute); 312

eman," which I know from my review of court records is the name of a law firm that currently represents GHISLAINE MAXWELL in civil litigation (the "Haddon, Morgan, & Foreman Phone"). The most recent contact between The Target Cellphone and the Haddon, Morgan, & Foreman Phone occurred within the last 30

4). It seems that a majority of courts in this district have rejected the claimed "standard practice" arguments made by the Government before Judge McMahon. A notable difference is that the other applications were not conducted ex parte. Review of the sealed materials further illustrates the point. One

Haddon, Morgan and Foreman. P.c Jeffrey Paglluca II A D D O N M OR G A N FOREMAN 303.832.2628 August 24, 2020 VIA EMAIL The Honorable Alison J. Nath

tracking device" for purposes of Rule 41 where used to collect location data); In re Application, 2009 WL 159187, at *5 *6 (S.D.N.Y. Jan.13, 2009) (McMahon, J.) (same). 3 See 18 U.S.C. § 3121 (prohibiting use of pen register or trap and trace device without an order under the pen register statute); 312

eman," which I know from my review of court records is the name of a law firm that currently represents GHISLAINE MAXWELL in civil litigation (the "Haddon, Morgan, & Foreman Phone"). The most recent contact between The Target Cellphone and the Haddon, Morgan, & Foreman Phone occurred within the last 30

tracking device" for purposes of Rule 41 where used to collect location data); In re Application, 2009 WL 159187, at *5 *6 (S.D.N.Y. Jan.13, 2009) (McMahon, J.) (same). 3 See 18 U.S.C. § 3121 (prohibiting use of pen register or trap and trace device without an order under the pen register statute); 312

eman," which I know from my review of court records is the name of a law firm that currently represents GHISLAINE MAXWELL in civil litigation (the "Haddon, Morgan, & Foreman Phone"). The most recent contact between Target Cellphone-1 and the Haddon, Morgan, & Foreman Phone occurred in or about February

tracking device" for purposes of Rule 41 where used to collect location data); In re Application, 2009 WL 159187, at *5 *6 (S.D.N.Y. Jan.13, 2009) (McMahon, J.) (same). 3 See 18 U.S.C. § 3121 (prohibiting use of pen register or trap and trace device without an order under the pen register statute); 312

eman," which I know from my review of court records is the name of a law firm that currently represents GHISLAINE MAXWELL in civil litigation (the "Haddon, Morgan, & Foreman Phone"). The most recent contact between The Target Cellphone and the Haddon, Morgan, & Foreman Phone occurred within the last 30

N April 22, 2021 The Hon. Alison J. Nathan United States District Court Judge Southern District of New York 40 Foley Square New York, NY 10007 Haddon. Morgan and Foreman, P.0 Jeffrey S. Pagliuca 150 East I Oth Avenue Denver, Colorado 80203 PH 303.831.7364 EX 303.832.2628 wvv.hmftaw.com jpogli

inal) (quoting Mincey v. Arizona, 437 U.S. 385, 398 (1978)). Here, the government violated due process when it misrepresented and misled Chief Judge McMahon in an ex pane proceeding to circumvent the civil protective order, and it independently would violate due process for the government to be allowed