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EFTA00808433 RICE PUGATCH ROBINSON STORFER & COHEN, PLLC 101 •. Third Avenue, Suite 1800 Ft. Laud
were resolved in July 2010, and each of the Intervenors executed a full release in favor of Epstein. Any attempt to relitigate the settled 'In the Response, the Intervenors' counsel uses the improper label "victims" 51 times to describe the Intervenors and "sexual abuse" or "sexual assault" 10 times. E
Avenue Denver, CO 80203 Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 100
I. The Government's Response to Maxwell's Motion. Confronted with evidence of AUSA misrepresentations to Judge McMahon, the government has filed a Response reluctantly admitting that the U.S. Attorney's Office had sustained contact with Boies Schiller in 2016. Even so, the government tries its best to m
EMAN P.C. Denver Phone: Christian R. Everdell COHEN & GRESSER LLP New York NY Phone: Bobbi C. Stem
constitutes an impermissible constructive amendment and variance to the Indictment. Finally, what is clear from the government's proffer in their Response, the anticipated testimony o will serve as an improper constructive 13 EFTA00090739 amendment to, and an impermissible variance of, the Indictm
ON, MORGAN & FOREMAN P.C. Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Sternheim Law Offices of
the court, the use of the qualifier made the question fundamentally ambiguous requiring dismissal of the count. The government, at page 133 of its Response, incorrectly suggests that the burden was on Ms. Maxwell or her counsel to clarify the confused questions, particularly regarding the infinite time
Entities connected to both Michael Cohen and Response

Jeffrey Epstein
PERSON
Barry Diller
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Donald Trump
PERSONJeffrey Pagliuca
PERSON
Marc Rich
PERSON
United States
LOCATION
Denver
LOCATION
Department of Justice
ORGANIZATION
George W. Bush
PERSONLaura Menninger
PERSONSouthern District
LOCATION
Colorado
LOCATIONCohen & Gresser LLP
ORGANIZATION
Julie K. Brown
PERSON
Stephen Hawking
PERSON
Alan Dershowitz
PERSON
William Barr
PERSON