Epstein Secrets

ecution of Potential Co-Conspirators Is Not Limited to the SDFL. 18 1. The NPA is binding on the USAO in this District 18 2. United States v. Annabi does not alter the analysis. 19 a. There is an "affirmative appearance" that the co-conspirator immunity provision was intended to apply outsid

20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS SUPERSEDING INDICTMENT FOR BREACH OF NON-PROSECUTION AGREEMENT Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Bobbi C. Stemheim Law Offices o

ecution of Potential Co-Conspirators Is Not Limited to the SDFL. 18 1. The NPA is binding on the USAO in this District 18 2. United States v. Annabi does not alter the analysis. 19 1. There is an "affirmative appearance" that the co-conspirator immunity provision was intended to apply outsid

that Ms. Maxwell be permitted to take discovery in aid of such I hearing. Dated: January 25, 2021 New York, New York Respectfully submitted, /s/ Mark S. Cohen Attorneys for Ghislaine Maxwell 32 EFTA00099388 CERTIFICATE OF SERVICE I hereby certify that on January 25, 2021, I served by email, pursuant R

bail proceeding, that are not even foreclosed by the cases the government does cite to you. They cite to you the -- I'm going to skip this one, the Annabi case, A-N-N-A-B-I case, which says, "The plea the office of the U.S. Attorney for the plea is entered unless it affirmatively agreement binds onl

ES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &