Epstein Secrets

cagni Kanefsky Certilman Balin Clifford Chance Cohen & Gresser Cohen Milstein Cravath Swaine Davido

berg Defamation Suit `',Law360 Pro Say Podcast Listen to our new podcast here LAW FIRMS Akin Gump Arnold & Porter Baker Botts Berger Montague Boies Schiller Briggs and Morgan Buchanan Ingersoll Calcagni Kanefsky Certilman Balin Clifford Chance Cohen & Gresser Cohen Milstein Cravath Swaine Davidof

GG COHEN & GRESSER LLP Mark S. Cohen Christian R Fverdell March 15, 2021 VIA ECF T

me-Barred 3. Reply Memorandum in Support of Motion Under the Due Process Clause to Suppress All Evidence Obtained from the Government's Subpoena to Boies Schiller and to Dismiss Counts Five and Six 4. Reply Memorandum in Support of Motion to Dismiss Counts Five and Six of the Superseding Indictment Because t

between those 2 had to respond immediately to these false charges. 2 folks if they disagree about that. But as to 3 which is what I did. 3 Mrs. Cohen. we're adamant she has a right to he 4 I need to take a break. 4 there and there's no legitimate basis for 5 MR. SCOTT: Take recess for a coupl

Y: Right. And I just want to 3 representations that there wouldn't be any 4 be clear. Mr. Epstein's counsel has not 4 testimony with respect to Boies Schiller 5 appeared in this case. I argued this issue 5 Flexner or those allegations that have 6 before the judge. and I have a confidentiality 6 repe

ies Schiller Buschel & Gibbons Cassin & Cassin Cohen Milstein Consovoy McCarthy Covington & Burling

ast here LAW FIRMS Akerman Arent Fox Baker Botts Baker Donelson Baker McKenzie BakerHostetler Ballard Spahr Banner Witcoff Berger Montague Boies Schiller Buschel & Gibbons Cassin & Cassin Cohen Milstein Consovoy McCarthy Covington & Burling Dentons Desai Law Firm PC Drinker Biddle Duval & Stac

ffice for the Southern District of New York Mark Cohen Christian Everdell Cohen & Gresser LLP Laura A

tion that it properly was a recipient of the material: [W]hatever Cooper & Kirk's intentions in requesting and obtaining the Maxwell materials from Boies Schiller, the Maxwell Protective Order explicitly provides that (1) discovery materials designated CONFIDENTIAL cannot be EFTA00075057 Caest 131-63.403481

ot to perform at the time the promise was made." Cohen v. Koenig, 25 F.3d 1168, 1172 (2d Cir. 1994). He

OEC 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 All right. OK. I know people personally and professionally at Boies Schiller. I knew Mr. Haddon when I was in private practice. I may know people at Steptoe, but I'm not sure. Nothing about any of that affects anything that

federal ;:',,Law360 Practice Groups of the Year LAW FIRMS Alva & Gleizer Arnold & Porter Barclay Damon Berger Montague Berke-Weiss Law PLLC Boies Schiller Cleary Gottlieb Covington & Burling Cravath Swaine Davis Wright Tremaine Debevoise & Plimpton Dechert Dentons Diserio Martin Earthjustice E

company spun out by Dell EMC and VMware, Andrew Cohen earlier this year helped establish a software in

e Denver, CO 80203 Phone: 303-831-7364 Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800

o prosecutors for the purpose of fomenting an investigation. But I am not faced with that situation. Nothing in this record suggests to me that or Boies Schiller had anything to do with the Government's decision to convene a grand jury to look into the matters that were the subject of the Action. On the con

slaine Maxwell, through counsel, respectfully moves to suppress under the due process clause all evidence obtained from the government's subpoena to Boies Schiller and to dismiss Counts Five and Six. Dated: January 25, 2021 New York, New York EFTA00023047 --- PAGE BREAK --- Respectfully submitted, s/ Jef

& FOREMAN P.C. Denver CO 80203 Phone: Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP New

Menninger HADDON MORGAN & FOREMAN P.C. Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Bobb

oena. INTRODUCTION AND SUMMARY OF THE ARGUMENT Counts Five and Six allege that Maxwell committed perjury during two civil depositions conducted by Boies Schiller in a defamation action it filed against Maxwell on behalf of one of the firm's clients. v. Marvell, Case No. 15-cv-7433 (LAP) (S.D.N.Y). A Protecti