Epstein Secrets

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 Silvio I. Motto Building January 10, 2021 Bobbi

or to trial."' (quoting United States v. Gibson, 175 F. Supp. 2d 532, 537 (S.D.N.Y. 2001))); United States v. Barrera, 950 F. Supp. 2d 461, 478-79 (E.D.N.Y. 2013) (denying motion for bill of particulars as to identities of unnamed victims of alleged murder conspiracy); United States v. Castro, No. 08 Cr

e let us know if you have any questions or would like to discuss the foregoing. Very truly yours, AUDREY STRAUSS Acting United States Attorney for the Southern District of New York By: s/ / / Assistant United States Attorneys 4 EFTA00023913

y retirement in 1998. As a Special Agent, I worked on numerous financial fraud investigations, including several with the U.S. Attorney's Office for the Southern District of New York. In addition, during the last five years of my employment with the IRS, I received the designation of Cross-Designation Authority from the FBI whil

including workers payroll records and invoices, and detailing any fraud discovered in final summary reports. 5. For this engagement, I was hired by Cohen & Gresser LLP to conduct an independent review of a Financial Condition Report prepared by Macalvins Accountants summarizing the financial condition and assets o

GHISLAINE MAXWELL IN SUPPORT OF HER MOTION TO DISMISS COUNTS ONE THROUGH FOUR OF THE SUPERSEDING INDICTMENT AS TIME-BARRED Christian R. Everdell COHEN & GRESSER LLP Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Phone:

States v. Sensi, No. 08 Cr. 253, 2010 WL 2351484 (D. Conn. June 7, 2010) 5 United States v. Vickers, No. 13 Cr. 128 (RJA) (HKS), 2014 WL 1838255 (W.D.N.Y. May 8, 2014) 15 Vernon v. Cassadaga Valley Cent. School Dist., 49 F.3d 886 (2d Cir. 1995) 9 iii EFTA00028906 --- PAGE BREAK --- Weingarten

TO BOLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Ghislaine Maxwell EFTA00028929 --- PAGE BREAK --- Table of Contents Table of

on first began. None of these statements by AUSA to Judge McMahon were true. As described above, attorneys pressed the U.S. Attorney's Office for the Southern District of New York to investigate and prosecute Epstein and Maxwell. Ex. J. Then, two months after the meeting with AUSA attorneys told Judge Sweet—who was presiding

THE SUPERSEDING INDICTMENT FOR PRE-INDICTMENT DELAY Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Ghislaine Maxwell EFTA00028963 --- PAGE BREAK --- The significant delay in pr

2d Cir.2000); Granite Partners, L.P. v. Bear, Stearns & Co., Inc., 184 F.R.D. 49, 54 (S.D.N.Y. 1999); Worthington v. Endee, 177 F.R.D. 113, 116-17 (N.D.N.Y. 1998); Peck v. United States, 514 F. Supp. 210, 213 (S.D.N.Y.), on reargument, 522 F. Supp. 245 (S.D.N.Y. 1981); State of N. D. ex reL Olson v. And

LLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON MORGAN & FOREMAN P.C. Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Chislaine Maxwell EFTA00029077 --- PAGE BREAK --- TABLE OF CONTENTS TABLE OF

ed by Boies Schiller in a defamation action it filed against Maxwell on behalf of one of the firm's clients. v. Marvell, Case No. 15-cv-7433 (LAP) (S.D.N.Y). A Protective Order entered in that case prohibited the parties and their lawyers from sharing confidential discovery material (including the two

TO BOLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Sternheim Attorneys for Ghislaine Maxwell EFTA00029100 --- PAGE BREAK --- Table of Contents Table of Contents Fable of Authorities

on first began. None of these statements by AUSA to Judge McMahon were true. As described above, attorneys pressed the U.S. Attorney's Office for the Southern District of New York to investigate and prosecute Epstein and Maxwell. Ex. J. Then, two months after the meeting with AUSA attorneys told Judge Sweet—who was presiding

ed by Boies Schiller in a defamation action it filed against Maxwell on behalf of one of the firm's clients. v. Marvell, Case No. 15-cv-7433 (LAP) (S.D.N.Y). A Protective Order entered in that case prohibited the parties and their lawyers from sharing confidential discovery material (including the two

ully submitted, s/ Jeffrey S. Pagliuca Jeffrey S. Pagliuca Laura A. Menninger HADDON MORGAN & FOREMAN P.C. Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Chislaine Maxwell 17 EFTA00029837 --- PAGE BREAK --- Certificate of Service

K Yes K No Do you or does any member of your family or a close friend personally know or have past or present dealings with the U.S. Attorney for the Southern District of New York, Damian Williams, or anyone else who works for or used to work for the U.S. Attorney's Office for the Southern District of New York? K Yes K No 3

lly know or have past or present dealings with any of the defense attorneys or law firms who are representing the Defendant: Christian Everdell of Cohen & Gresser LLP a Yes K No Jeffrey Pagliuca of Haddon, Morgan and Foreman, P.C. a Yes K No Laura Menninger of Haddon, Morgan and Foreman, P.C. K Yes o No Bobbi S