Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x S2 20 Cr. 330 (AJN) UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x MS. MAXWELL'S MOTION FOR AN ORDER AUTHORIZING A SUBPOENA PURSUANT TO FED. R. CRIM. P 17(c)(3) Jeffrey S. Pagliuca Laura A

ED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x S2 20 Cr. 330 (AJN) UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x MS. MAXWELL'S MOTION FOR AN ORDER AUTHORIZING A SUBPOENA PURSUANT TO FED. R. CRIM. P 17(c)(3) Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN

nninger HADDON, MORGAN & FOREMAN P.C. Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi . Stemheim Attorneys for Chislaine Maxwell EFTA00040126 Defendant Ghislaine Maxwell requests that the Court enter an Order authorizing her counsel to issue a subpoena under Federal Rule of

F AMERICA v. GHISLAINE MAXWELL, Defendant. x MS. MAXWELL'S MOTION FOR AN ORDER AUTHORIZING A SUBPOENA PUR

667, 684, (1985). Full and complete cross-examination of the Accusers is impossible without understanding the complete terms of the agreement with the Epstein Fund, including the claims concerning Ms. Maxwell, as well as others. Cf. Moore v. Marr, 254 F.3d 1235, 1244 (10th Cir. 2001) (noting that witnesses' "a

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) MS. MAXWELL'S MOTION FOR AN ORDER AUTHORIZING A SUBPOENA PURSUANT TO FED. R. CRIM. P 17(c)(3) Jeffrey

ED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) MS. MAXWELL'S MOTION FOR AN ORDER AUTHORIZING A SUBPOENA PURSUANT TO FED. R. CRIM. P 17(c)(3) Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN

ue New York NY 10022 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 225 Broadway, Suite 715 New York NY 10007 Phone: Attorneys for Chislaine Maxwell EFTA00105542 Defendant Ghislaine Maxwell requests that the Court enter an Order authorizing her counsel to issue a subpoena under Federal Rule of

INE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) MS. MAXWELL'S MOTION FOR AN ORDER AUTHORIZING A SUBPOENA PUR

667, 684, (1985). Full and complete cross-examination of the Accusers is impossible without understanding the complete terms of the agreement with the Epstein Fund, including the claims concerning Ms. Maxwell, as well as others. Cf. Moore v. Marr, 254 F.3d 1235, 1244 (10th Cir. 2001) (noting that witnesses' "a

rable Alison J. Nathan United States District Judge Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (MN) Dear Judge Nathan: The Government respectfully submits this letter motion to quash the defendant's Rule 17(c)(3) subpoena to

New York, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (MN) Dear Judge Nathan:

te cross-examination is impossible without understanding the complete terms of the agreement with the Epstein Fund, including the claims concerning Maxwell, as well as others." (Def. Mot. at 6). Materials are not relevant and admissible at trial, as required by Nixon, simply because they aid the defenda

impeachment information because "[f]ull and complete cross-examination is impossible without understanding the complete terms of the agreement with the Epstein Fund, including the claims concerning Maxwell, as well as others." (Def. Mot. at 6). Materials are not relevant and admissible at trial, as required by

rable Alison J. Nathan United States District Judge Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (MN) Dear Judge Nathan: The Government respectfully submits this letter motion to quash the defendant's Rule 17(c)(3) subpoena to-t

te cross-examination is impossible without understanding the complete terms of the agreement with the Epstein Fund, including the claims concerning Maxwell, as well as others." (Def. Mot. at 6). Materials are not relevant and admissible at trial, as required by Nixon, simply because they aid the defenda

New York, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (MN) Dear Judge Nathan:

impeachment information because "[f]ull and complete cross-examination is impossible without understanding the complete terms of the agreement with the Epstein Fund, including the claims concerning Maxwell, as well as others." (Def. Mot. at 6). Materials are not relevant and admissible at trial, as required by