Epstein Secrets

2018) 8, 15 Hampton v. United States, 425 U.S. 484 (1976) 20 In re WinNet R CISC, 2017 WL 1373918 (S.D.N.Y. No. 16MC484(DLC), Apr. 13, 2017) 24 Martindell v. Intl Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979) 18, 21 McNabb v. United States, 318 U.S. 332 (1943) 20 Morales v. Portuondo, 165 F. Supp.

ISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New

Obtained in Violation of the Sixth Amendment 10. Motion for a Bill of Particulars and Pretrial Disclosures II. Motion Under the Fourth Amendment, Martindell, and the Fifth Amendment to Suppress All Evidence Obtained from the Government's Subpoena to and to Dismiss Counts Five and Six 12. Motion to Dism

lease contact us with any questions. Your consideration is greatly appreciated. Respectfully submitted, /s/ Mark S. Cohen Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York New York 10022 cc: All counsel of record (via email) EFTA00095655

losures EFTA00097329 The Honorable Alison J. Nathan March 15, 2021 Page 2 II. Reply Memorandum in Support of Motion Under the Fourth Amendment, Martindell, and the Fifth Amendment to Suppress All Evidence Obtained from the Government's Subpoena to and to Dismiss Counts Five and Six 12. Reply Memoran

with proposed redactions. Please contact us with any questions. Your consideration is greatly appreciated. Respectfully submitted, Is/ Christian R. Everdell Christian R. Everdell COHEN & GRESSER LLP cc: All counsel of record (via email) For documents that the government has designated as "Confidentia