3
Shared Docs
3
Same-Page
3 / 3
Mentions
st levied her accusations more than a decade ago. The Palm Beach FBI and the United States Attorney's Office for the Southern District of Florida ("USAO-SDFL") interviewed Accuser-4 in or around 2007 during their three- year investigation of Epstein's alleged sexual abuse (the "Florida Investigation"). And
he Double Jeopardy Clause, and (3) grant her other requested relief. Dated: May 7, 2021 New York, New York Respectfully submitted, Is/ Christian R. Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &
secutorial overreach. It is no mystery what happened here. The Palm Beach FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO-SDFL") conducted a thorough investigation of Jeffrey Epstein from 2006-2008 (the "Florida Investigation"), but decided not to prosecute him or his "pote
ements as Brady material, and (4) grant her other requested relief. Dated: May 28, 2021 New York, New York Respectfully submitted, Is/ Christian R. Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue ISO Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East
squarely refutes the government's position. The co-conspirator immunity provision does not prohibit merely prosecutions by the USAO for the SDFL ("USAO-SDFL"), but by "the United States." This broad prohibition was intentional, as demonstrated by the express references elsewhere in the NPA to the United
ANDUM 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 of Bobbi C. Stemheim At
Entities connected to both USAO-SDFL and R. Everdell

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Michael Cohen
PERSON
United States
LOCATIONJeffrey Pagliuca
PERSONCohen & Gresser LLP
ORGANIZATIONthe Southern District
LOCATION
Southern District of New York
ORGANIZATIONMORGAN & FOREMAN
ORGANIZATIONMark S. Cohen
PERSONSecond Circuit
ORGANIZATION
Department of Justice
ORGANIZATION
Denver
LOCATIONJane Doe
PERSON
Prince Andrew
PERSON
Kenneth Marra
PERSON
Colorado
LOCATIONEmmy Taylor
PERSON
Bradley Edwards
PERSON
Harvey Weinstein
PERSON