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of underage girls." Id. In the joinder motion, also alleged she was "forced" to have sex with Harvard law professor Alan Dershowitz, "model scout" Jean Luc Brunel, and "many other powerful men, including numerous prominent American politicians, powerful business executives, foreign presidents, a well-known Pr
professor Alan Dershowitz, "model scout" Jean Luc Brunel, and "many other powerful men, including numerou
aw professor Alan Dershowitz, "model scout" Jean Luc Brunel, and "many other powerful men, including numerou
MISSTATEMENTS ARE NOT PERJURIOUS AS A MATTER OF LAW Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim Attorneys for Ghislaine Maxwell EFTA00097378 TABLE OF CONTENTS TABLE OF CONTENTS i TABL
conditions she has proposed. " Any incentive Ms. Maxwell might have to flee to Fiance has been greatly diminished by the recent arrest in France of Jean-Luc Brunel. who reportedly is under investigation for alleged sexual assaults by Jeffrey Epstein. See. e.g.. France Derails Modeling Agent in Jeffrey Epstein I
ished by the recent arrest in France of Jean-Luc Brunel. who reportedly is under investigation for allege
iminished by the recent arrest in France of Jean-Luc Brunel. who reportedly is under investigation for allege
suant to the conditions she has proposed. Dated: December 4, 2020 Respectfully submitted, /s/ Mark S. Cohen Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver,
conditions she has proposed. S Any incentive Ms. Maxwell might have to flee to France has been greatly diminished by the recent arrest in France of Jean-Luc Brunel, who reportedly is under investigation for alleged sexual assaults by Jeffrey Epstein. See, e.g., France Details Modeling Agent in Jeffrey Epstein I
Page: EFTA00016782 →ished by the recent arrest in France of Jean-Luc Brunel, who reportedly is under investigation for allege
Page: EFTA00016782 →iminished by the recent arrest in France of Jean-Luc Brunel, who reportedly is under investigation for allege
Page: EFTA00016782 →iry. 10 EFTA00016782 --- PAGE BREAK --- Dated: December 18, 2020 Respectfully submitted, is/Marks Cohen Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver,
Page: EFTA00016783 →conditions she has proposed. 8 Any incentive Ms. Maxwell might have to flee to France has been greatly diminished by the recent arrest in France of Jean-Luc Brunel, who reportedly is under investigation for alleged sexual assaults by Jeffrey Epstein. See, e.g., France Details Modeling Agent in Jeffrey Epstein I
Page: EFTA00019304 →ished by the recent arrest in France of Jean-Luc Brunel, who reportedly is under investigation for allege
Page: EFTA00019304 →iminished by the recent arrest in France of Jean-Luc Brunel, who reportedly is under investigation for allege
Page: EFTA00019304 →. 10 EFTA00019304 --- PAGE BREAK --- Dated: December 18, 2020 Respectfully submitted, /s/ Mark S. Cohen Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Ave
Page: EFTA00019305 →TO BOLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Sternheim Attorneys for Ghislaine Maxwell EFTA00029100 --- PAGE BREAK --- Table of Contents Table of Contents Fable of Authorities
Page: EFTA00029100 →photos were found on or produced from any computers associated with Maxwell. 2 EFTA00029106 --- PAGE BREAK --- o That Maxwell and Epstein-friend Jean Luc Brunel "took sexually explicit photos of [M] regularly."2 Id. o That, as a birthday present, Maxwell gave Epstein a sexually explicit photo of taken whe
Page: EFTA00029107 →K --- o That Maxwell and Epstein-friend Jean Luc Brunel "took sexually explicit photos of [M] regularly
Page: EFTA00029107 →BREAK --- o That Maxwell and Epstein-friend Jean Luc Brunel "took sexually explicit photos of [M] regularly
Page: EFTA00029107 →Entities connected to both Jean-Luc Brunel and Cohen & Gresser LLP

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Michael Cohen
PERSON
T-Mobile
ORGANIZATIONJeffrey Pagliuca
PERSON
Bradley Edwards
PERSON
Alan Dershowitz
PERSON
Marc Rich
PERSONLeon Black
PERSONDarren Indyke
PERSONLaura Menninger
PERSON
United States
LOCATION
Donald Trump
PERSONJane Doe
PERSONSouthern District
LOCATION
Bill Clinton
PERSON
Department of Justice
ORGANIZATION
Joe Biden
PERSONJack Goldberger
PERSON