Epstein Secrets

r seal will be subject to a press request to unseal it, we need to ensure at the outset that we only mark things as confidential that the Court (and Second Circuit) will view as such when making an unsealing determination, so we included a definition of "Confidential" consistent with the case law. See, e.g., B

coveryiAJNU_Del_edits.pdf Inline-Images: image001.jpg; image002.png; image005.jpg Happy to discuss a response to this if it would be useful. From: Christian Everdell Sent: Friday, July 17, 2020 12:11 AM To: Cc: Mark S. Cohen Subject: Protective Order and >; ; Jeff Pagliuca c ; 'Laura Menninger' Laura Menn

(USANYS)" Cc: ' (USANYS)" Subject: Re: U.S. v. Ghislaine Maxwell Date: Wed, 31 Mar 2021 15:01:54 +0000 We are preparing our motion for bail in the Second Circuit and need to inform the Court of the government's position. We intend to let the Court know that the Government's opposes Ms. Maxwell's motion and in

(USANYS) • > Sent: Thursday, March 25, 2021 7:10 PM To: David Oscar Markus Cc: Mark S. Cohen Subject: RE: U.S. v. Ghislaine Maxwell David, ; Christian Everdell; Bobbi Sternheim ►; Thanks for letting us know that you'll be counsel on this appeal. As an initial matter, the majority of the docket entries you

ictment are so general that they do not advise the defendant of the specific acts of which he is accused." United States v. Walsh, 194 F.3d 37, 47 (2d Cir. 1999) (quotations marks and citation omitted); see also, e.g., United States v. Mahabub, No. 13 Cr. 908 (MN), 2014 WL 4243657, at *2 (S.D.N.Y. Aug.

U.S. Department of Justice United States Attorney Southern District of New York By Electronic Mail Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon Mor an and Foreman, P.C. Dear Counsel: The Silv

ictment are so general that they do not advise the defendant of the specific acts of which he is accused." United States v. Walsh, 194 F.3d 37, 47 (2d Cir. 1999) (quotations marks and citation omitted); see also, e.g., United States v. Mahabub, No. 13 Cr. 908 (MN), 2014 WL 4243657, at *2 (S.D.N.Y. Aug.

U.S. Department of Justice United States Attorney Southern District of New York By Electronic Mail Christian Everdell, Esq. Mark Cohen, Esq. ohen & Gresser LLP Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon Mor an and Foreman, P.C. Dear Counsel: The Silvi

legislative history at issue did not clearly evidence Congress' intent regarding retroactivity. Id. That is not the case here. As Judge Katzman of the Second Circuit has recognized, unambiguous legislative history should not be disregarded: When courts construe statutes in ways that respect what legislators cons

suant Rule 2(B) of the Court's individual practices in criminal cases, the within memorandum and any accompanying exhibits upon the following: /s/ Christian Everdell EFTA00103733

llate matters in this case. In particular, Mr. Markus has handled the defendant's bail appeals in this case, including an argument on her behalf in the Second Circuit. As the Court may recall, on April 14, 2021, Mr. Markus emailed Chambers requesting permission to bring electronics to the courthouse to attend the

mitted, AUDREY STRAUSS United States Attorney By: Is Assistant United States Attorneys Southern District of New York Tel: (212) 637-2225 Cc: Christian Everdell, Esq. (by ECF) Mark Cohen, Esq. (by ECF) Bobbi Sternheim, Esq. (by ECF) Laura Menninger, Esq. (by ECF) Jeffrey Pagliuca, Esq. (by ECF) David Mar

r seal will be subject to a press request to unseal it, we need to ensure at the outset that we only mark things as confidential that the Court (and Second Circuit) will view as such when making an unsealing determination, so we included a definition of "Confidential" consistent with the case law. See, e.g., B

ender by telephone or return e-mail and delete the original transmission and its attachments without reading or saving it in any manner. Thank you. Christian Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 I view bio www.cohengresser.com New York I Seoul I Paris I Washington DC I London CONF

rrelevant allegations in an indictment or information, which may, however, be prejudicial." Fed. R. Crim. P. 7(d) Advisory Committee's Note. In the Second Circuit, Fed. R. Crim. P. 7(d) motions may be granted "where the challenged allegations are not relevant to the crime charged and are inflammatory and preju

within memorandum and any accompanying exhibits upon the following: U.S. Attorney's Office, SDNY One Saint Andrew's Plaza New York, NY 10007 /s/ Christian Everdell EFTA00086751

t in this District as barred by what they claimed was an earlier "plea agreement" in the Eastern District, and the court denied the motion. Id. The Second Circuit, in affirming the denial, stated simply that "[I] plea agreement binds only the office of the United States Attorney for the district in which the p

within memorandum and any accompanying exhibits upon the following: U.S. Attorney's Office, SDNY One Saint Andrew's Plaza New York, NY 10007 /s/ Christian Everdell EFTA00099389

[email protected]> Sent: Wednesday, March 31, 2021 11:02 AM To: Subject: Re: U.S. v. Ghislaine Maxwell We are preparing our motion for bail in the Second Circuit and need to inform the Court of the government's position. We intend to let the Court know that the Government's opposes Ms. Maxwell's motion and in

EAK --- markuslaw.com 305-379= From (USANYS) ausdoLgov> Sent: Thursday, March 25, 2021 7:10 PM To: David Oscar Markus Cc: (USANYS) (USANYS); Christian Everdell; Bobbi Sternheim ([email protected]). Mark S. Cohen Subject: RE: U.S. v. Ghislaine Maxwell David, Thanks for letting us know that you'll be cou