Epstein Secrets

apply any redactions to that document; rather, the redactions existed on the document at the time the document was found during the FBI's search of Epstein's devices. We are not aware of any legal basis for your request for a log of redactions. If you have any EFTA00030914 --- PAGE BREAK --- legal au

r used to track Ms. Maxwell's cellphone before her arrest (https://www.thedailybeast.com/how- the-fbi-tracked-down-ghislaine-maxwell-alleged-madam-of-jeffrey-epstein). The article stated that the affidavit appeared in a "newly unsealed court filing." I don't recall this affidavit being unsealed or referenced in a

or any other materials from the criminal discovery, and whether any discovery materials were released pursuant to FOIA requests. Regards, COHEN & GRESSER LLP Eltil l I view bto www.cohengresser.com New York I Pans I Washington DC I London CONFIDENTIALITY NOTICE: The information contained in this e-mail

r used to track Ms. Maxwell's cellphone before her arrest (https://www.thedailybeast.com/how- the-fbi-tracked-down-ghislaine-maxwell-alleged-madam-of-jeffrey-epstein). The article stated that the affidavit appeared in a "newly unsealed court filing." I don't recall this affidavit being unsealed or referenced in a

the criminal discovery, and whether any discovery materials were released pursuant to FOIA requests. Regards, Chris Christian R Everdell COHEN & GRESSER LLP EFTA00021737 --- PAGE BREAK --- www.cohengresser.com view bio New York I Paris I Washington DC I London CONFIDENTIALITY NOTICE: The informatio

ached). Please provide the missing attachments, if they exist. 4. A number of electronic documents — over 110,000 — that were extracted from one of Epstein's devices, as identified by a CART number, have metadata that indicates a "date created" or "date last modified" date in July 2020 or afterwards (s

intentional or are we missing those documents? Please let us know your responses as soon as possible. Thanks, Chris Christian R Everdell COHEN & GRESSER LLP Elti n I view bio www.cohengresser.com New York I Paris I Washington DC I London EFTA00027862 --- PAGE BREAK --- CONFIDENTIALITY NOTICE: The i

sq. Cohen 8: Gresser LLP Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Mor an and Foreman, P.C.

epartment of Justice United States Attorney Southern District of New York BY ELECTRONIC MAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen 8: Gresser LLP Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Mor an and Foreman, P.C. Bobbi Sternheim, Esq. Law Offices of Bobbi C. Sternheim April 23,

OLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

ir. 1996) 2 Young v. United States, 481 U.S. 787 (1987) 24 Other Authorities Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020) 11 U.S. Dept. of Justice, JUSTICE MANUAL, JM § 9-11.151 15 Rules Fed.

al abuse and trafficking by Jeffrey Epstein and Maxwell. Ex. J, pp 1-3. • At the meeting, attorneys told AUSA the following: o That Maxwell was Epstein's "head recruiter" of underage victims. Id. at 2. o That was underage when she was brought to New York "for training by Maxwell and Epstein [in] h

TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi . Stemheim Attorneys for Chislaine Maxwell EFTA00029816 --- PAGE BREAK --- TABLE OF CONTENTS TABLE OF

r, "An Appeal to Lillian Hellman and Mary McCarthy," 5/11/80 New York Times 2 Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020) 9 Rules Fed. R. Civ. P. 1 12 Constitutional Provisions U.S. CONST. am

ing a time- honored if unfortunate litigation tactic, her lawyers at Boies Schiller therefore sought to turn the lawsuit into a proxy prosecution of Epstein. Not surprisingly, discovery in the case was bitter, hard-fought, and wide-ranging. It spanned more than a year and included large document product

re not recovered from the searched devices. We do not have them, which is why they were not produced. • For #4, the electronic files recovered from Epstein's devices have the same metadata on the hard drive that was available when the FBI seized each file. For files that were carved or deleted, no metad

intentional or are we missing those documents? Please let us know your responses as soon as possible. Thanks, Chris Christian R Everdell COHEN & GRESSER LLP MLE I view bio www.cohengresser.com New York I Paris I Washington DC I London CONFIDENTIALITY NOTICE: The information contained in this e-mail m

them. That said, similar to the note I sent in my email regarding highly confidential images on March 16, 2021, the electronic files recovered from Epstein's devices have the same metadata on the hard drive that was available when the FBI seized each file. For files that were carved or deleted, no metad

intentional or are we missing those documents? Please let us know your responses as soon as possible. Thanks, Chris Christian R Everdell COHEN & GRESSER LLP Eltil l I view bio www.cohengresser.com New York I Paris I Washington DC I London CONFIDENTIALITY NOTICE: The information contained in this e-mai

them. That said, similar to the note I sent in my email regarding highly confidential images on March 16, 2021, the electronic files recovered from Epstein's devices have the same metadata on the hard drive that was available when the FBI seized each file. For files that were carved or deleted, no metad

intentional or are we missing those documents? Please let us know your responses as soon as possible. Thanks, Chris Christian R Everdell COHEN & GRESSER LLP Eltil l I view bio www.cohengresser.com New York I Pans I Washington DC I London CONFIDENTIALITY NOTICE: The information contained in this e-mail

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

spectfully submitted, s/ Jeffrey S. Pagliuca 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 4 EFTA00028972 --- PAGE BREAK --- Certificate of Service