Epstein Secrets

v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: The Government writes regarding your request to review sixteen (16) discs in the possession of the Federal Bureau of Investigation ("FBI") as part of the file previously maintained by the FBI's Palm Beach Resident Agency (the "FBI Florida Office") during its investigation of Je

J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 April 9, 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 Foreman, P.C. 150 East Tenth Avenue Denver

in or around September 2007' including five enumerated offenses; (2) 'any other offenses that have been the subject of the joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office'; and (3) 'any offenses that arose from the Federal Grand Jury investigation.' 5 EFTA00103766 (Dkt. 20

S MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER SUPPLEMENTAL PRETRIAL MOTIONS RELATING TO THE S2 SUPERSEDING INDICTMENT 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,

on and indictment by the Florida State Attorney's Office, the recitals state, among other things, that (i) the "United States Attorney's Office" and the Federal Bureau of Investigation ("FBI") have "conducted their own investigation into Epstein's background and any offenses that may have been committed by Epstein against the Unite

LAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS SUPERSEDING INDICTMENT FOR BREACH OF NON-PROSECUTION AGREEMENT Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Ghislaine

Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: The Government expects to offer testimony fro of the Federal Bureau of Investigation's ("FBI") Computer Analysis Response Team ("CART"). As noted in the Government's September 15, 2021 letter, although the Government believes that te

rk The Silvio J. Mob Building One Saint Andrew's Plaza New York. Neu• York 10007 November 25, 2021 BY ELECTRONIC MAIL Christian Everdell, Esq. Cohen & Gresser LLP 800 Third Avenue New York, NY 10022 Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. 150 East Tenth Avenue Denver

Yes K No 29c. If yes to 29b, please explain: 30. Do you know or have any association—professional, business, or social, direct or indirect—with the Federal Bureau of Investigation, commonly known as the FBI? K Yes K No 30a. If yes, please explain: -15- EFTA00077981 Juror ID: 30b. If yes to 30, would this affect your ab

lly know or have past or present dealings with any of the defense attorneys or law firms who are representing the Defendant: Christian Everdell of Cohen & Gresser LLP K Yes a No Jeffrey Pagliuca of Haddon, Morgan and Foreman, P.C. K Yes a No Laura Menninger of Haddon, Morgan and Foreman, P.C. K Yes a No Bobbi S

: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: The Government expects to offer testimony from Computer Forensic Examiner of the Federal Bureau of Investigation's ("FBI") Com uter Analysis Response Team ("CART"). Although the Government believes that Examiner testimony will not require admission through Rule

Mob Building One Saint Andrew's Plaza New York. New York 10007 September 15, 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 Foreman, P.C. 150 East Tenth Avenue Denver

ant with perjury, in violation of 18 U.S.C. § 1623. 2 EFTA00093266 Caged 20-ZNEOGNAMit Dbeu ftki6t1 2I112 1F 822033/e0gEFIgec6 On July 2, 2020, the Federal Bureau of Investigation ("FBI") arrested the defendant. Following extensive briefing, on July 14, 2020, the Court held a lengthy bail hearing. In its written and oral subm

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,

ollo Building One Saint Andrew's Plaza New York, New York 10007 February 26, 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 Foreman, P.C. 150 East Tenth Avenue Denver

se Pretrial Motion Number 10 for Bill of Particulars and Pre-Trial Disclosures in this case, is On or about November 14, 2006, was interviewed by the Federal Bureau of Investigation. The notes from that interview contain the following line on page 12: "rumor is that JE is gay," apparently referring to a rumor regarding Jeffrey

Mollo Building One Saint Andrew's Plaza New York, New York 10007 August 21, 2020 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 Foreman, P.C. 150 East Tenth Avenue Denver

Palm Beach Police Department and Florida Materials Confidential This production includes certain materials from the files of the Florida office of the Federal Bureau of Investigation ("FBI"). The Government notes that the remainder of the Florida FBI Files in PDF format designated as "confidential" under the protective order have

es K No "'Se. If yes to 28b, please explain: 29. Do you know or have any association—professional, business, or social, direct or indirect—with the Federal Bureau of Investigation, commonly known as the FBI? o Yes o No 29a. If yes, please explain: -15- EFTA00032837 --- PAGE BREAK --- Juror ID: 29b. If yes to 29, would

lly know or have past or present dealings with any of the defense attorneys or law firms who are representing the Defendant: Christian Everdell of Cohen & Gresser LLP a Yes K No Jeffrey Pagliuca of Haddon, Morgan and Foreman, P.C. a Yes K No Laura Menninger of Haddon, Morgan and Foreman, P.C. K Yes o No Bobbi S