Epstein Secrets

S MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER SUPPLEMENTAL PRETRIAL MOTIONS RELATING TO THE S2 SUPERSEDING INDICTMENT Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver,

ere arrested at Kennedy Airport on November 23, 1982, in possession of four kilograms of heroin and were charged in a three-count indictment in the Eastern District of New York with (I) conspiracy to import heroin into the United States, (2) a substantive offense of importing heroin, and (3) possession of heroin

Y MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER SUPPLEMENTAL PRETRIAL MOTIONS RELATING TO THE S2 SUPERSEDING INDICTMENT Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, Colorado

s opinion that the defendants did not have a Double Jeopardy claim because they "were never in jeopardy with respect to the dismissed counts of the Eastern District indictment." Annabi, 771 F.2d at 671. The court was clear that the defendants' only claim on appeal was that the Southern District indictment "viol

LAINE 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 of Bobbi C. Stemheim Attorneys for Ghislaine

); United States v. Ashraf, 320 F. App'x 26, 28 (2d Cir. 2009) (plea agreement "by its express terms, bound only the U.S. Attorney's Office for the Eastern District of Virginia"); Gonzalez, 93 F. App'x at 270 ("Paragraph 13 explicitly states that the agreement binds only the United States Attorney's Office for t