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

he claims are evaluated per the Protocol which credits "[w]hether there exists any information and/or pertinent findings offered by the appropriate Office of the District Attorney, United States Attorney's Office, or other law enforcement agency." Accordingly, the Protocol credits claimants who have had charges filed

EXHIBIT A UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. X No. 20 Cr. 330 (MN) Declaration of in support of Motion to Quash Rule 17(c) Subpoena pursuant to 28 U.S.C. § 1746, decla

individuals and entities. 2. I respectfully submit this declaration in support of the motion to quash a subpoena directed to me by the defendant Ghislaine Maxwell for certain documents submitted to, communications with, and payments issued by the EVCP. I have personal knowledge of the facts set forth in this

and without condition is essential to the integrity and success of this Program, and the viability of other similar compensation programs. 16. Ms. Maxwell's motion seeking authorization for this subpoena makes inaccurate statements about the Protocol. Ms. Maxwell's motion expressed that "the Protocol c

ity of other similar compensation programs. 16. Ms. Maxwell's motion seeking authorization for this subpoena

considered in evaluating claims. One of those factors was "Whether there exists any information and/or pertinent findings offered by the appropriate Office of the District Attorney, United States Attorney's Office, or other law enforcement agency." (Protocol at 5-6.) The Protocol does not use the term "credit" nor doe

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

he claims are evaluated per the Protocol which credits "[w]hether there exists any information and/or pertinent findings offered by the appropriate Office of the District Attorney, United States Attorney's Office, or other law enforcement agency." Accordingly, the Protocol credits claimants who have had charges filed