Epstein Secrets

HADDON MORGAN FOREMAN May 12, 2021 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Haddon, Morgan and Foreman. r.c Jeffrey Paglluca

ernment Letters dated May 4, and May 6, 2021 Regarding F.R. Crim. P. 17(c) Subpoena, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, On March 15, 2021, Ms. Maxwell asked the Court to issue a F.R.Crim.P. 17(c)(3) subpoena for production of evidence controlled by Boies, Schiller,

12, 2021 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Haddon, Morgan and Foreman. r.c Jeffrey Paglluca Denver. Colorado 80203 Re: Response to Government Letters dated May 4, and May 6, 2021 Regarding F.R. Crim. P. 17(c) Subpo

Filed 10/14/21 Page 1 of 3 Haddon, Morgan and Foreman. r.c Jeffrey Paglluca HADDON MORGAN FOREMAN Pfr October 14, 2021 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 ISO East 10th Avenue Denver. Colorado 80203 www.

www.hmflaw.com Re: Deadline for Filing Motion under Federal Rule of Evidence 412, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, I write to confirm that November 15, 2021 is the deadline for Ms. Maxwell to file a motion under Federal Rule of Evidence 412, which governs the a

Case 1:20-cr-00330-AJN Document 345 Filed 10/14/21 Page 1 of 3 Haddon, Morgan and Foreman. r.c Jeffrey Paglluca HADDON MORGAN FOREMAN Pfr October 14, 2021 VIA ECF The Honorable Alison J. Nathan United States District Court Southe

H A D D O N MORGAN FOREMAN August 17, 2020 VIA EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: Request to Modify Protective Order (UNDER SEA

.c Jeffrey Paglloca 150 East 10th Avenue Denver, Colorado 80203 rti 303.831.7364 FX 303.832.2628 www.hmflaw.com jpaglucaahmflaw.com Dear Judge Nathan, Defendant Ghislaine Maxwell, pursuant to paragraph 18 of this Court's Protective Order (Doc. # 36), requests that the Court enter an Order allowin

ork 40 Foley Square New York, NY 10007 Re: Request to Modify Protective Order (UNDER SEAL)' United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Haddon, Morgan and Foreman, t.c Jeffrey Paglloca 150 East 10th Avenue Denver, Colorado 80203 rti 303.831.7364 FX 303.832.2628 www.hmflaw.com jpaglucaahmflaw.com Dear Jud

ion absent "further order of the Court." Protective Order, 20 Cr. 330 (MN) at 1(a), 18 (Exhibit A). As required by that Protective Order and Judge Nathan's Individual Practices in Criminal Cases, counsel initiated a conferral with the U.S. Attorney's Office over the weekend concerning a modification

ed States District Court outhern District of New York ew or 0007 Re: Au 3, 2020 Order (Doc. 1096) v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Haddon, Morgan and Foreman, P C Laura A. Menninger Denver, Colorado 80203 wvow.hmilaw.com Dear Judge Preska: I write in response to the Court's Order of August 3, 2020 (Do

Maxwell, No. 15 Civ. 7433 (LAP) and a related appeal in the United States Court of Appeals for the Second Circuit, 20-2413. We intend to ask Judge Nathan for permission to refer to and attach, as exhibits, the above referenced discovery materials which relate to the Government's efforts to obtain civ

H A D D O N MORGAN FOREMAN Haddon, Morgan and Foreman, P c Jeffrey S. Paglluca P11 IIIIIIIMPPOIMIIIMPIIIMPIO www.hmflaw.com August 9, 2020 VIA EMAIL Assistant United States Attorney New York, New

ur baseless accusations of malfeasance in the civil litigation—accusations you now know to be false. Moreover, the Protective Order issued by Judge Alison J. Nathan in the above-referenced criminal case expressly provides that any and all discovery material produced to the defendant by the Government, regardles

of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New lark 10007 August 12, 2020 VIA EMAIL Jeffrey S. Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, CO 80203 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Mr. Pagliuca: The Government writes i

investigation, and their public disclosure at this stage risks interference with that investigation. Moreover, the Protective Order issued by Judge Alison J. Nathan in the above-referenced criminal case expressly provides that any and all discovery material produced to the defendant by the Government, regardless

of New York The Silvio J. Motto Building One Saint Andrew's Plaza New York. New York 10007 August 12, 2020 VIA EMAIL Jeffrey S. Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, CO 80203 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Mr. Pagliuca: The Government writes i

Cr. 330 (AJN) Discovery request pertaining to FOIA productions Dear Counsel: I write to request certain discovery pursuant to Fed. R. Cr. P. 16. Haddon, Morgan and Foreman, e c Laura A. Menninger Denver Colorado 80203 www.hmflow.com Under Rule 16(a)(1)(E), I ask that you provide to us the documents produced by the F

rough the FOIA requests, the dates the documents were produced and the identity of the recipient of the documents. Finally, in your letter to Judge Nathan of October 7, 2020, you represented that your "Prosecution Team ... had no involvement in the Florida Investigation." (Dkt. 63 at 4.) You defined y

REMAN July 29, 2020 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, P.0 Ty Gee 150 East 10th Avenue Denver, Colorado 80203 ni 303.831.7364 rx 303.832.2628 www.hmtlaw.com tgeefghmflaw.com Re: Reconsideration of

r potential witnesses that going forward it will not hesitate to take appropriate action in the face of violations of any relevant rules." Id. judge Nathan said she would ensure "strict compliance" with the rules and "ensure that the Defendant's right to a fair trial will be safeguarded." Id. On July