Epstein Secrets

aine Maxwell , who requests this subpoena, are: Jeffrey S. Pagliuca, Haddon, Morgan & Foreman P.C., 150 E

-mail, and telephone number of the attorney representing blame of party) Ghislaine Maxwell , who requests this subpoena, are: Jeffrey S. Pagliuca, Haddon, Morgan & Foreman P.C., 150 East 10th Ave., Denver, Colorado 80203, Notice to those who use this form to request a subpoena Before requesting and serving a subpoena pursu

refers to any submission to the Epstein Victim's Compensation Program made by an Accuser, including any claims on behalf of persons who have accused Jeffrey Epstein or Ghislaine Maxwell of any misconduct, any releases signed by an Accuser or their Attorneys, and any compensation received by an Accuser. INSTRUCT

ntary, independent Program that has been established to compensate and resolve the claims of victims-survivors of sexual abuse by Jeffrey Epstein ("Epstein"). The Estate of Jeffrey Epstein (the "Estate") has retained the services of nationally recognized claims administration experts Kenneth R. Feinber

aine Maxwell , who requests this subpoena, are: Jeffrey S. Pagliuca. Haddon, Morgan & Foreman P.C., 150 E

-mail, and telephone number of the attorney representing blame of party) Ghislaine Maxwell , who requests this subpoena, are: Jeffrey S. Pagliuca. Haddon, Morgan & Foreman P.C., 150 East 10th Ave., Denver, Colorado 80203, Notice to those who use this form to request a subpoena Before requesting and serving a subpoena pursu

refers to any submission to the Epstein Victim's Compensation Program made by an Accuser, including any claims on behalf of persons who have accused Jeffrey Epstein or Ghislaine Maxwell of any misconduct, any releases signed by an Accuser or their Attorneys, and any compensation received by an Accuser. INSTRUCT

ny owner, shareholder, partner or employee of the Epstein Victim's Compensation Program ("EVCP"), and any

ristian R. Everdell COHEN & GRESSER LLP Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

INDICTMENT FOR BREACH OF THE NON-PROSECUTION AGREEMENT Christian R. Everdell COHEN & GRESSER LLP Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Phone: Attorneys for Ghislaine Maxwell EFTA00028880 --- PAGE BREAK --- TABLE OF CO

7 United States v. Van Thornout, 100 F.3d 590 (8th Cir. 1996) 12 Other Authorities Dienst, J., Valiquette, J., Winter, T., and Fitzpatrick, S. "Jeffrey Epstein Confidante Ghislaine Maxwell Arrested on Sex Abuse Charges." NBC New York. July 3, 2020 15 iii EFTA00028883 --- PAGE BREAK --- Ghislaine Maxw

of the NPA states, without limitation, that "the United States .. . will not institute any criminal charges against any potential co-conspirators of Epstein." Because the Superseding Indictment ("Indictment") contends that Ms. Maxwell was a co-conspirator of Epstein, the NPA, on its face, applies here.

ristian R. Everdell COHEN & GRESSER LLP Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

OUGH FOUR OF THE SUPERSEDING INDICTMENT AS TIME-BARRED Christian R. Everdell COHEN & GRESSER LLP Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Phone: Attorneys for Ghislaine Maxwell EFTA00028903 --- PAGE BREAK --- TABLE OF CO

OF THE SUPERSEDING INDICTMENT AS MULTIPLICITOUS Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

OF HER MOTION TO DISMISS EITHER COUNT ONE OR COUNT THREE OF THE SUPERSEDING INDICTMENT AS MULTIPLICITOUS Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Ghislaine Maxwell EFTA00028968 ---

00 Third Avenue New York, NY 10022 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

and will continue to receive throughout the duration of the trial and (ii) the extensive prior negative publicity concerning Ghislaine Maxwell and Jeffrey Epstein. The intense negative media coverage of Ms. Maxwell and Epstein, most profoundly in the aftermath of his death in August 2019 and the arrest of Ms.

ii) the extensive prior negative publicity concerning Ghislaine Maxwell and Jeffrey Epstein. The intense negative media coverage of Ms. Maxwell and Epstein, most profoundly in the aftermath of his death in August 2019 and the arrest of Ms. Maxwell in July 2020, has significantly increased the likelihoo

(Barry Levin) • Jeffrey Epstein's Other Women: Behind Ghislaine Maxwell (Lisa Tait) • The Jeffrey Epstein Case: What We Do and Don't Know About Je •ey Epstein and Ghislaine Maxwell (Stephen Wright) Much of the pretrial reporting, publications, and broadcasts refer to Epstein's 2008 case in Florida and th

Epstein Case: What We Do and Don't Know About Je •ey Epstein and Ghislaine Maxwell (Stephen Wright) Much of

GOVERNMENT EXHIBITS 251, 288, 294, 313 AND 606 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

. Maxwell The photographs have no probative value to any allegation in this case and appear to be offered to demonstrate some character flaw in Mr. Epstein and, by association, Ms. Maxwell. Government Exhibit 294 is a box containing an item described as "Twin Torpedos." This box was apparently seized

be offered to demonstrate some character flaw in Mr. Epstein and, by association, Ms. Maxwell. Government Ex

from a DVD disk in a binder found on a shelf in Jeffrey Epstein's house when it was searched in 2012. There is n

e-mail, and telephone number of the attorney representing blame of party) Ghislaine Maxwell , who requests this subpoena, are: Jeffre S. Pa huca. Haddon, Morgan & Foreman P.C., Notice to those who use this form to request a subpoena Before requesting and serving a subpoena pursuant to Fed. R. Crim. P. 17(c), the party see

refers to any submission to the Epstein Victim's Compensation Program made by an Accuser, including any claims on behalf of persons who have accused Jeffrey Epstein or Ghislaine Maxwell of any misconduct, any releases signed by an Accuser or their Attorneys, and any compensation received by an Accuser. INSTRUCT

ntary, independent Program that has been established to compensate and resolve the claims of victims-survivors of sexual abuse by Jeffrey Epstein ("Epstein"). The Estate of Jeffrey E stein (the "Estate") has retained the services of nationally recognized claims administration experts and .MNIIMMMMENIM

e by Jeffrey Epstein ("Epstein"). The Estate of Jeffrey E stein (the "Estate") has retained the services of

-mail, and telephone number of the attorney representing blame of party) Ghislaine Maxwell , who requests this subpoena, are: Jeffrey S. Pagliuca. Haddon, Morgan & Foreman P.C., 150 East 10th Ave., Denver, Colorado 80203, Notice to those who use this form to request a subpoena Before requesting and serving a subpoena pursu

refers to any submission to the Epstein Victim's Compensation Program made by an Accuser, including any claims on behalf of persons who have accused Jeffrey Epstein or Ghislaine Maxwell of any misconduct, any releases signed by an Accuser or their Attorneys, and any compensation received by an Accuser.

any submission to the Epstein Victim's Compensation Program made by an Accuser, including any claims on behalf of persons who have accused Jeffrey Epstein or Ghislaine Maxwell of any misconduct, any releases signed by an Accuser or their Attorneys, and any compensation received by an Accuser. INSTRUCT

rogram") is a voluntary, independent Program that has been established to compensate and resolve the claims of victims-survivors of sexual abuse by Jeffrey Epstein ("Epstein"). The Estate of Jeffrey Epstein (the "Estate") has retained the services of nationally recognized claims administration'. Kenneth R. Fei

SUBPOENA T AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON MORGAN &

identiary hearing on this Motion. Dated: January 25, 2021 Respectfully submitted, s/ Jeffrey S. Pagliuca Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Denver, CO 80203 Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim e w or c. 1%WR0 1