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acteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualiz
r 1, 2021 VIA EMAIL United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon Morgan and Foreman, P.0 Jeffrey S. PairBoca 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364
cepted theory of grooming by third parties or empirical evidence regarding the prevalence, characteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualized massages for herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed mi
Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon
ey. As trial preparation proceeds, the defense will update the topics for Mr. Kelso if any arise. F. John Lopez Mr. Lopez was a Special Agent with the United States Department of the Treasury, Internal Revenue Service, Criminal Investigation ("IRS-CI") for over twenty-five years. During his tenure at IRS-CI, Mr. Lopez led the New York As
r 1, 2021 VIA EMAIL United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Haddon, Morgan and Foreman, P.0 Jeffrey S. Pagliuca 150 East lOth Avenue Denver, Colorado 80203 www.hrnflaw.com Dear Counsel:
cepted theory of grooming by third parties or empirical evidence regarding the prevalence, characteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualized massages for herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed mi
Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Haddon, Morgan and For
acteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualiz
he government through . As trial preparation proceeds, the defense will update the topics for Mr. if any arise. F. Mr. was a Special Agent with the United States Department of the Treasury, Internal Revenue Service, Criminal Investigation ("IRS-CI") for over twenty-five years. During his tenure at IRS-CI, Mr. I= led the New York Asse
Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon,
r 1, 2021 VIA EMAIL United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon, Morgan and Foreman, P.0 Jeffrey S. Pagliuca 150 East lOth Avenue Denver, Colorado 80203 www.hrnflaw.com
acteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualiz
cepted theory of grooming by third parties or empirical evidence regarding the prevalence, characteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualized massages for herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed mi
ent through Ste hen ey. As trial preparation proceeds, the defense will update the topics for Mr. if any arise. F. Mr. was a Special Agent with the United States Department of the Treasury, Internal Revenue Service l ' • al Investigation ("IRS-CI") for over twenty-five years. During in his tenure at IRS-CI, Mr. led the New York
r 1, 2021 VIA EMAIL United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon Morgan and Foreman, P.0 Jeffrey S. Paglitica 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364
cepted theory of grooming by third parties or empirical evidence regarding the prevalence, characteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualized massages for herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed mi
Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon
acteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualiz
government through M=. As trial preparation proceeds, the defense will update the topics for Mr. Kelso if any arise. F. was a Special Agent with the United States Department of the Treasury, Internal Revenue ServiceCriminal Investigation ("IRS-CI") for over twenty-five years. During his tenure at IRS-CI, led the New York Asset Forfeit
r 1, 2021 VIA EMAIL United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AIN) Dear Counsel: Haddon Morgan and Foreman, P.0 Jeffrey S. Paglluca 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364
cepted theory of grooming by third parties or empirical evidence regarding the prevalence, characteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualized massages for herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed mi
Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AIN) Dear Counsel: Haddon
acteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualiz
government through M=. As trial preparation proceeds, the defense will update the topics for Mr. Kelso if any arise. F. was a Special Agent with the United States Department of the Treasury, Internal Revenue ServiceCriminal Investigation ("IRS-CI") for over twenty-five years. During his tenure at IRS-CI, led the New York Asset Forfeit
w York New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon,
acteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualiz
RGAN FOREMAN November 1, 2021 VIA EMAIL United States Attorney's Office Southern District of New York New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon, Morgan and Foreman, P.0 Jeffrey S. Pagliuca Denver, Colorado 80203 PH FX www.hmflaw.com JPagliuca@hmf
cepted theory of grooming by third parties or empirical evidence regarding the prevalence, characteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualized massages for herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed mi
ey. As trial preparation proceeds, the defense will update the topics for Mr. Kelso if any arise. F. John Lopez Mr. Lopez was a Special Agent with the United States Department of the Treasury, Internal Revenue Service, Criminal Investigation ("IRS-CI") for over twenty-five years. During his tenure at IRS-CI, Mr. Lopez led the New York As
thern District of New York Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon,
Page: EFTA00016268 →H A D D O N MORGAN FOREMAN November 1, 2021 VIA EMAIL United States Attorney's Office Southern District of New York Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: Haddon, Morgan and Foreman, P.0 Jeffrey S. Paglitica PH Fx www.hmflaw.com Defendant Ghislaine Maxwell through
Page: EFTA00016268 →cepted theory of grooming by third parties or empirical evidence regarding the prevalence, characteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualized massages for herself. Instead, the claim appears to be that Ms. Maxwell recruited and groomed mi
Page: EFTA00016271 →acteristics, or mechanisms of such a phenomenon. Ms. Maxwell is not accused of soliciting or enticing sexualiz
Page: EFTA00016271 →ey. As trial preparation proceeds, the defense will update the topics for Mr. Kelso if any arise. F. John Lopez Mr. Lopez was a Special Agent with the United States Department of the Treasury, Internal Revenue Service, Criminal Investigation ("IRS-CI") for over twenty-five years. During his tenure at IRS-CI, Mr. Lopez led the New York As
Page: EFTA00016280 →Entities connected to both Ghislaine Maxwell and the United States Department of the Treasury

Jeffrey Epstein
PERSON
Prince Andrew
PERSONSouthern District
LOCATION
United States
LOCATION
Bill Clinton
PERSON
Department of Justice
ORGANIZATION
Marc Rich
PERSONJeffrey Pagliuca
PERSON
Virginia Giuffre
PERSON
Denver
LOCATION
Stephen Hawking
PERSON
Colorado
LOCATION
Bloomberg L.P.
ORGANIZATION
Lawrence Krauss
PERSON
Paul Ryan
PERSON
Foreman
PERSONHaddon
PERSON
U.S. Treasury
ORGANIZATION
Jennifer Lopez
PERSON
Steve Bannon
PERSON