Epstein Secrets

Accuser-3's testimony that includes the points discussed above. Dated: October 18, 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 &

n the grounds that they could not support the charged conspiracies and were unfairly prejudicial to Ms. Maxwell. See Def.'s Mem. in Supp. of Mot. to Strike Surplusage from Superseding Indictment (Dkt. 146) at 1-3, 6-9. Ms. Maxwell noted that (1) according to Accuser-3's own allegations, she was above the legal ag

20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO STRIKE SURPLUSAGE FROM SUPERSEDING INDICTMENT Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.

g), 108 Stat. 1796 6 iii EFTA00086739 PRELIMINARY STATEMENT Ghislaine Maxwell respectfully submits this Memorandum in Support of her Motion to Strike Surplusage from the Indictment ("Motion"). Although Ms. Maxwell is charged with conspiring to cause individuals to travel in interstate or foreign commerce to

Accuser-3's testimony that includes the points discussed above. Dated: October 18, 2021 New York, New York Respectfully submitted, Is/ Christian R. Everdell Christian R. Everdell COHEN & GRESSER LLP New York, NY Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Denver, CO

n the grounds that they could not support the charged conspiracies and were unfairly prejudicial to Ms. Maxwell. See Def.'s Mem. in Supp. of Mot. to Strike Surplusage from Superseding Indictment (Dkt. 146) at 1-3, 6-9. Ms. Maxwell noted that (1) according to Accuser-3's own allegations, she was above the legal ag

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

Not Penurious as a Matter of Law 5. Motion for a Severance of and Separate Trial on Counts Five and Six of the Superseding Indictment 6. Motion to Strike Surplusage from the Superseding Indictment 7. Motion to Dismiss Counts One Through Six of the Superseding Indictment for Pre- Indictment Delay 8. Motion to Di