Epstein Secrets

t) will view as such when making an unsealing determination, so we included a definition of "Confidential" consistent with the case law. See, e.g., Brown v. Maxwell. A few notes to explain specific changes. 1. We have clarified treatment of non-confidential discovery materials from confidential disco

coveryiAJNU_Del_edits.pdf Inline-Images: image001.jpg; image002.png; image005.jpg Happy to discuss a response to this if it would be useful. From: Christian Everdell Sent: Friday, July 17, 2020 12:11 AM To: Cc: Mark S. Cohen Subject: Protective Order and >; ; Jeff Pagliuca c ; 'Laura Menninger' Laura Menn

489 U.S. 726 (1989) 15 Food and Drug Admin. v. Brown & Williamson Tobacco Corp., 529 U.S. 120 (2000)

suant Rule 2(B) of the Court's individual practices in criminal cases, the within memorandum and any accompanying exhibits upon the following: /s/ Christian Everdell EFTA00103733

.61M), among other news outlets, also report on the charges filed against Cooper. Douglass Statue Torn Down In Rochester. The Washington Post (7/6, Brown, 14.2M) reports that a statue of "famous abolitionist and orator Frederick Douglass was torn from its pedestal in Rochester, N.Y., on Sunday, the 16

extreme risk of flight.' The AP (7/6) reports, "In a letter to a judge on Sunday, prosecutors say they communicated with Maxwell's defense lawyer, Christian Everdell, who would like a Friday bail hearing after written arguments are submitted by both sides Thursday and Friday. She will also be arraigned at the he

taping him,' she added. 'Friends don't tape friends." Maxwell Reportedly Hires "El Chapo" Prosecutors As Defense Attorney. The New York Post (7/7, Brown, 4.57M) reports, "Ghislaine Maxwell has hired the former prosecutor who helped bring down drug kingpin Joaquin 'El Chapo' Guzman to try to get her o

d sex- trafficking charges." According to the Post, "Recent court filings for the 58-year-old British media heiress show that she is being repped by Christian Everdell, who spent more than a decade as an assistant US attorney for the Southern District of New York. Everdell's bio notes how he and his team were awar

t) will view as such when making an unsealing determination, so we included a definition of "Confidential" consistent with the case law. See, e.g., Brown v. Maxwell. A few notes to explain specific changes. 1. We have clarified treatment of non-confidential discovery materials from confidential disco

ender by telephone or return e-mail and delete the original transmission and its attachments without reading or saving it in any manner. Thank you. Christian Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 I view bio www.cohengresser.com New York I Seoul I Paris I Washington DC I London CONF

nd human behavior at the Alpert Medical School of Brown University. The Government reserves the right to

Southern District of New York The Silvio J. Mollo Building One saint Andrew's Plaza New York, New York 10007 April 23, 2021 BY ELECTRONIC MAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP 800 Third Avenue New York, NY 10022 Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and

nd human behavior at the Alpert Medical School of Brown University. The Government reserves the right to

U.S. Department of Justice United States Attorney Southern District of New York BY ELECTRONIC MAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon. Morgan and Foreman, P.C. Bobbi Stemheim, Esq.

ers of the media thereafter.' I See Stephen Rex Brown, Ghislaine Marvell Makes First Court Appearance,

mitted, AUDREY STRAUSS United States Attorney By: Is Assistant United States Attorneys Southern District of New York Tel: (212) 637-2225 Cc: Christian Everdell, Esq. (by ECF) Mark Cohen, Esq. (by ECF) Bobbi Sternheim, Esq. (by ECF) Laura Menninger, Esq. (by ECF) Jeffrey Pagliuca, Esq. (by ECF) David Mar

02) United States v. Annabi, 771 F.2d 670 (2d Cir. 1985) United States v. Ashy*: 29 passim 320 F. App'x 26 (2d Cir. 2009) 22 United States v. Brown, No. 99-1230(L), 2002 WL 34244994 (2d Cir. Apr. 26, 2002) 23 United States v. CFW Const. Co., 583 F. Supp. 197 (D.S.C.), affd, 749 F.2d 33 (4th C

within memorandum and any accompanying exhibits upon the following: U.S. Attorney's Office, SDNY One Saint Andrew's Plaza New York, NY 10007 /s/ Christian Everdell EFTA00099389

closure of these materials to permit Defendant to make application to the U.S. Court of Appeals for the Second Circuit for a more extended stay."); Brown v. Maxwell, 929 F.3d 41, 54 (2d. Cir. 2019) (recognizing likelihood of future appeals in this matter). 1. There are new, intervening and significan

July 21, 2020 Page 7 Respectfully Submitted, Jeffrey S. Pagliuca cc: U.S. Attorney's Office for the Southern District of New York Mark Cohen Christian Everdell Cohen & Gresser LLP Laura A. Menninger Haddon, Morgan & Foreman, P.C. EFTA00075071 Cagesle120o140ZaUX.PertDo&Aflt."1016ZO. PEIR603824/20e1a4e20