Epstein Secrets

20 Cr. 330 (AJN) MEMORANDUM 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 o

); 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

l decide to appear by video from the MDC, Thursday or next Tuesday are the soonest spots available." The Post adds, "Hours later, Maxwell's attorney Mark S. Cohen said in a court filing that she `has agreed to waive her physical presence' for her court appearance. He asked for Nathan to schedule the case for

olice identified as part of the investigation, dubbed Operation Kick Boxer, by the Milwaukee Division of the FBI, the U.S. Attorney's Office of the Eastern District of Wisconsin, the National Center for Missing & Exploited Children and the Winnebago County Sheriff's Office." WGBA-TV Green Bay, WI (7/6) reports

that Ms. Maxwell be permitted to take discovery in aid of such I hearing. Dated: January 25, 2021 New York, New York Respectfully submitted, /s/ Mark S. Cohen Attorneys for Ghislaine Maxwell 32 EFTA00099388 CERTIFICATE OF SERVICE I hereby certify that on January 25, 2021, I served by email, pursuant R

); 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