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ESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Ghislaine Maxwell EFTA00065989 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 STATEMENT OF FACTS 7 A. The Structure of the NPA 8 B. The Negotiation of the
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. X 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS SUPERSEDING INDICTMENT FOR BREACH OF NO
OURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. X 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 & GRESS
ould Be Dismissed for Breach of the NPA. 14 A. Ms. Maxwell Has Standing to Enforce the NPA. 15 B. The NPA
.D.N.Y. 2002) (emphasis added) (holding that garment workers had standing as third-party beneficiaries to enforce wage compliance agreement between Department of Labor and clothing manufacturer that contracted with their employer); Florida Power & Light Co. v. Mid-Valley, Inc., 763 F.2d 1316, 1321 (11th Cir. 1985)
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. X 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS SUPERSEDING INDICTMENT FOR BREACH OF NO
OURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. X 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS SUPERSEDING INDICTMENT FOR BREACH OF NON-PROSECUTION AGREEMENT Attorneys for Ghislaine Maxwell EFTA00099352 TAB
AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS SUPERSEDING INDICTMENT FOR BREACH OF NON-PROSECUTION AGREEMENT Attorneys for Ghislaine Maxwell EFTA00099352 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 STATEMENT OF FACTS 7 U The Structure of the NPA 8 B. The Negotiation of the
hould Be Dismissed for Breach of the NPA. 14 a Ms. Maxwell Has Standing to Enforce the NPA. 15 B. The NPA
.D.N.Y. 2002) (emphasis added) (holding that garment workers had standing as third-party beneficiaries to enforce wage compliance agreement between Department of Labor and clothing manufacturer that contracted with their employer); Florida Power & Light Co. v. Mid-Valley, Inc., 763 F.2d 1316, 1321 (11th Cir. 1985)
s was charged just weeks after General Motors Co. alleged that he received funds from Fiat Chrysler to place former UAW vice president Joe Ashton on GM's board. The accusations came as part of a lawsuit by GM alleging that Fiat Chrysler got better contracts than competing automakers by bribing unio
"Williams, who headed the UAW from 2014- 18, is the second ex-president to be charged in an ongoing public corruption investigation by the FBI, IRS, Department of Labor and U.S. Attorney's Office. Gary Jones pleaded guilty in June to conspiring with other high-level union officials to embezzle over $1 million of uni
was charged just weeks after General Motors Co. alleged that he received funds from Fiat Chrysler to place former UAW vice president Joe Ashton on GM's board. The accusations came as part of a lawsuit by GM alleging that Fiat Chrysler got better contracts than competing automakers by bribing union
"Williams, who headed the UAW from 2014-18, is the second ex-president to be charged in an ongoing public corruption investigation by the FBI, IRS, Department of Labor and U.S. Attorney's Office. Gary Jones pleaded guilty in June to EFTA00149233 conspiring with other high-level union officials to embezzle over $1
have insurance are being left in the cold= Scott Maxwell in the Orlando Sentinel has it right about the s
agents, and federal prison employees stayed. The department con=inues running background checks for gun sales. Some attorneys have been=sent home.) Department of Labor: 82 percent of the 16,304 employees have been sent home. (Mine-safety inspectors stayed. Wage and occupational safety regulators were sent home. Em
was charged just weeks after General Motors Co. alleged that he received funds from Fiat Chrysler to place former UAW vice president Joe Ashton on GM's board. The accusations came as part of a lawsuit by GM alleging that Fiat Chrysler got better contracts than competing automakers by bribing union
"Williams, who headed the UAW from 2014-18, is the second ex-president to be charged in an ongoing public corruption investigation by the FBI, IRS, Department of Labor and U.S. Attorney's Office. Gary Jones pleaded guilty in June to conspiring with other high-level union officials to embezzle over $1 million of uni
n to recuse the judge, saying Thursday that its petition was unlikely to succeed. Order attached I Read full article » Epstein Accuser, Media Slam Maxwell's Bid To Shield Docs Crowell & Moring DLA Piper Davis Polk Davis Wright Tremaine Debevoise & Plimpton Dechert Edelson PC Foley & Lardner Fox
Page: EFTA00025527 →s and a raft of media organizations have slammed Ghislaine Maxwell's attempt to keep her depositions from a settled
Page: EFTA00025528 →s and a raft of media organizations have slammed Ghislaine Maxwell's attempt to keep her depositions from a
Page: EFTA00025528 →U.S. Department of Commerce U.S. Department of Health and Human Services U.S. Department of Homeland Security U.S. Department of Justice U.S. Department of Labor EFTA00025530 --- PAGE BREAK --- restaurant's registered trade dress that he personally found "demeaning" to goats. Read full article » Bank Of
Page: EFTA00025531 →Entities connected to both Ghislaine Maxwell and Department of Labor

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
United States
LOCATION
George W. Bush
PERSON
Bill Clinton
PERSON
Newark
LOCATION
Michael Cohen
PERSON
Department of Justice
ORGANIZATION
FedEx
ORGANIZATION
Marc Rich
PERSON
Donald Trump
PERSONLeon Black
PERSONthe Southern District
LOCATION
Eric Trump
PERSON
Julie K. Brown
PERSON
Virginia Giuffre
PERSON
New York
LOCATIONMaria Farmer
PERSONFBI
ORGANIZATION
Denver
LOCATION