Epstein Secrets

June 2, 2021 (Dkt. 297), we write to provide the government with the list of potential defense witnesses. Included on the list are three attorneys: Brad Edwards, Robert Glassman, and Jack Scarola. Pursuant to the Court's instruction, we will brief any privilege issues to the Court before offering their testi

. Included on the list are three attorneys: Brad Edwards, Robert Glassman, and Jack Scarola. Pursuant to t

panying this letter, we have also provided a hyperlink to a Sharefile containing the defense disclosures under Rule 26.2. Sincerely, Is/ Christian R. Everdell Christian R. Everdell cc: All counsel of record (by email) 2063779.1 EFTA00155648

. Included on the list are three attorneys: Brad Edwards, Robert Glassman, and Jack Scarola. Pursuant to t

June 2, 2021 (Dkt. 297), we write to provide the government with the list of potential defense witnesses. Included on the list are three attorneys: Brad Edwards, Robert Glassman, and Jack Scarola. Pursuant to the Court's instruction, we will brief any privilege issues to the Court before offering their testi

panying this letter, we have also provided a hyperlink to a Sharefile containing the defense disclosures under Rule 26.2. Sincerely, Is/ Christian R. Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 cc: All counsel of record (by email) 2063779.1

edly surfaced in connection with a former Epstein employee, Alfredo Rodriguez, now deceased. Mr. Rodriguez was attempting to sell the compilation to Brad Edwards, one of the lawyers who was involved in suing Mr. Epstein in 2009. According to the Criminal Complaint filed against Mr. Rodriguez in 2009, Mr. Rod

ez was attempting to sell the compilation to Brad Edwards, one of the lawyers who was involved in suing Mr

URCES Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303-831-7364 Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 225 Broadway,

ng and Contacts with Peter Skinner, Stan Pottinger, and Brad Edwards EXHIBIT L: Email String Between Peter Skinner and AUSA cc'ing Stan Pottinger, Brad Edwards, and Sigrid McCawley (Feb. 29, 2016—Mar. 5, 2016) (Sealed) EXHIBIT M: Emails between AUSA and Chief of the Criminal Division (Mar. 3, 2016) (Seale

rmation at issue is peculiarly within the possession of the government (e.g., AUSA and AUSA la or others who are adverse to Maxwell (e.g., Boies, Edwards, Skinner, Pottinger). See Cortina, 630 F.2d at 1216 ("The violation here is particularly insidious because it is difficult to uncover misrepresentat

ISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New

tine Maxwell Exhibit D. Letter of Katie Vaughan-Edwards Exhibit E. Letter of Kevin Maxwell Exhibit F.

AINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Denver, CO 80203 Phone: B