Epstein Secrets

ugust 12, 2020 VIA EMAIL Jeffrey S. Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, CO 80203 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Mr. Pagliuca: The Government writes in response to your letter dated August 9, 2020 requesting to use discovery materials p

awsuit. As an initial matter, the Government notes that it remains unclear whether you make this request in your capacity as defense counsel to Ms. Maxwell in the above-referenced criminal case, or in your capacity as her attorney in a separate civil matter. If the former, the Government maintains that

h Avenue Denver, CO 80203 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Mr. Pagliuca: Th

s request in your capacity as defense counsel to Ms. Maxwell in the above-referenced criminal case, or in you

g Materials is appropriate because they pertain to an ongoing grand jury investigation and because Chief Judge Colleen McMahon and Magistrate Judge Sarah Netburn have ordered that the Unsealing Materials remain under seal. The only exceptions to those sealing orders are the permission contained in Chief Judge

burn, We write today to request a pre-motion conference, pursuant to Local Civil Rule 37.2, to seek the Court's guidance as to compelling defendant Maxwell to produce requested documents. As the Court will recall, this is a case in which the plaintiff,M has alleged that she was sexually trafficked by

this is a case in which the plaintiff,M has alleged that she was sexually trafficked by Jeffrey Epstein and his co-defendants, including defendant Ghislaine Maxwell. Maxwell is the only one of the four defendants who did not invoke her Fifth Amendment right against self-incrimination to refuse to produce docume

ts. But in response to requests for production, Ms. Maxwell produced very little information. Following that

stein and his co-defendants, including defendant Ghislaine Maxwell. Maxwell is the only one of the four def

f Law at the University of Utah 383 S. University St. Salt Lake Cit UT 84112 Tele hone: December 13, 2018 VIA CM/ECF Honorable Magistrate Judge Sarah Netburn United States District Court Thurgood Marshall Courthouse 40 Foley Square, Rm 430 New York, NY 10007 Re: Jane Doe 43 v. Jeffrey Epstein, et at,

ellaneous Case is EFTA00080937 Page 2 active and ongoing, and indeed resulted in new charges being brought just this month. See United States v. Maxwell, 20 Cr. 330 (AJN). The existence of the Government's application related to its efforts to permit compliance with a grand jury subpoena, and the spe

criminal grand jury investigation, which, despite significant coverage in the media in connection with charges brought against Jeffrey Epstein and Ghislaine Maxwell, nevertheless continues to include matters not publicly known or confirmed through public filings or Government statements. The Government notes th

with charges brought against Jeffrey Epstein and Ghislaine Maxwell, nevertheless continues to include matte

ork The Silvio J. Moto Building One Saint Andrew's Plaza New York. New York 10007 July 22, 2020 TO BE FILED UNDER SEAL VIA EMAIL The Honorable Sarah Netburn United States District Court Southern District of New York United States Courthouse New York, New York 10007 Re: In re Application to Unseal Ci