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2016 in which certain of the Attorneys met with SDNY prosecutors to ask SDNY to initiate a criminal investigation into Mr. Epstein and Ms. Maxwell. See New York Daily News, "Manhattan Federal Prosecutors Declined to Pursue Jeffrey Epstein and Ghislaine Maxwell Case in 2016: Sources" (Oct. 13, 2020), https://www.nydail
erdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 (212) 957-7600 cc: Mark S. Cohen, Esq. Jeff Pagliuca, Esq. Laura Menninger, Esq. Bobbi C. Stemheim, Esq. EFTA00101102
2 (212) 957-7600 cc: Mark S. Cohen, Esq. Jeff Pagliuca, Esq. Laura Menninger, Esq. Bobbi C. Stemheim,
2016 in which certain of the Attorneys met with SDNY prosecutors to ask SDNY to initiate a criminal investigation into Mr. Epstein and Ms. Maxwell. See New York Daily News, "Manhattan Federal Prosecutors Declined to Pursue Jeffrey Epstein and Ghislaine Maxwell Case in 2016: Sources" (Oct. 13, 2020), https://www.nydail
Is/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 cc: Mark S. Cohen, Esq. Jeff Pagliuca, Esq. Laura Menninger, Esq. Bobbi C. Stemheim, Esq. EFTA00101110
k, New York 10022 cc: Mark S. Cohen, Esq. Jeff Pagliuca, Esq. Laura Menninger, Esq. Bobbi C. Stemheim,
es in the area, induding The Homegrown Connection." The Sun Journal article is also posted to the Central Maine (7/21, 21K) website. The Bangor (ME) Daily News (7/21, 198K) and the WMTW-TV Portland, ME (7/21, 105K) website also cover this story. First Person Arrested As Result Of DO3 Operation Facing Drug C
her sex crimes case to impose a gag order on lawyers and others to reduce prejudicial pretrial publicity and protect her chances of a fair trial." Jeffrey Pagliuca "filed a letter in Manhattan federal court citing public comments made by Acting U.S. Attorney Audrey Strauss, the head of New York's FBI office and
nd protect her chances of a fair trial." Jeffrey Pagliuca "filed a letter in Manhattan federal court citing
while arguing with a man on the street." The officer "was suspended without pay on Sunday after videos of the incident went viral on social media." The New York Daily News <https://www.nydailynews.corn/new-york/nyc-crime/ny-times-square-rally-fights- 20201025-nisr4casijctdftvhkxwmsmpse-story.html> (10/25, Annese, 2.52M)
Bloomberg, "The government's failure to provide the evidence makes it impossible for Maxwell to prepare her defense, the British socialite's lawyer Jeffrey Pagliuca said Friday in a letter to U.S. District Judge Alison Nathan." As an illustration, the indictment does not provide exact "dates for when Maxwell co
ration, the indictment does not provide exact "dates for when Maxwell committed the alleged crimes, only saying they occurred between 1994 and 1997, Pagliuca said." He wrote, "Neither the indictment nor the discovery inform Ms. Maxwell about critical information necessary to prepare her defense." Teenag
2016 in which certain of the Attorneys met with SDNY prosecutors to ask SDNY to initiate a criminal investigation into Mr. Epstein and Ms. Maxwell. See New York Daily News, "Manhattan Federal Prosecutors Declined to Pursue Jeffrey Epstein and Ghislaine Maxwell Case in 2016: Sources" (Oct. 13, 2020), https://www.nydail
vance for your attention to these matters. Sincerely, Is/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP cc: Mark S. Cohen, Esq. Jeff Pagliuca, Esq. Laura Menninger, Esq. Bobbi C. Stemheim, Esq. EFTA00066073
HEN & GRESSER LLP cc: Mark S. Cohen, Esq. Jeff Pagliuca, Esq. Laura Menninger, Esq. Bobbi C. Stemheim,
hile arguing with a man on the street." The officer "was suspended without pay on Sunday after videos of the incident went viral on social media." The New York Daily News (10/25, Annese, 2.52M) reports that during the Times Square clash, "protesters hollered curses at former mayor Rudy Giuliani," who said he "wasn't p
Bloomberg, "The government's failure to provide the evidence makes it impossible for Maxwell to prepare her defense, the British socialite's lawyer Jeffrey Pagliuca said Friday in a letter to U.S. District Judge Alison Nathan." As an illustration, the indictment does not provide exact "dates for when Maxwell com
ation, the indictment does not provide exact "dates for when Maxwell committed the alleged crimes, only saying they occurred between 1994 and 1997, Pagliuca said." He wrote, "Neither the indictment nor the discovery inform Ms. Maxwell about critical information necessary to prepare her defense." Teenag
2016 in which certain of the Attorneys met with SDNY prosecutors to ask SDNY to initiate a criminal investigation into Mr. Epstein and Ms. Maxwell. See New York Daily News, "Manhattan Federal Prosecutors Declined to Pursue Jeffrey Epstein and Ghislaine Maxwell Case in 2016: Sources" (Oct. 13, 2020), https://www.nydail
Is/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 cc: Mark S. Cohen, Esq. Jeff Pagliuca, Esq. Laura Menninger, Esq. Bobbi C. Stemheim, Esq. EFTA00087054
k, New York 10022 cc: Mark S. Cohen, Esq. Jeff Pagliuca, Esq. Laura Menninger, Esq. Bobbi C. Stemheim,
duously refrained from any involvement with the media, despite repeated, persistent and borderline-harassing requests for comment. The statements in the New York Daily News Op-Ed piece were from Mr. Markus, who is not counsel of record in this case. These statements did not violate Rule 23.1. Nevertheless, it is approp
client does not deserve to be tried."). Respectfully submitted: /s/ Bobbi C. Stemheim /s/ Christian R. Everdell Is/ Laura A. Menninger Is/ Jeffrey S. Pagliuca cc: Government counsel David Oscar Markus, Esq. 3 EFTA00087798
verdell Is/ Laura A. Menninger Is/ Jeffrey S. Pagliuca cc: Government counsel David Oscar Markus, Esq.
2016 in which certain of the Attorneys met with SDNY prosecutors to ask SDNY to initiate a criminal investigation into Mr. Epstein and Ms. Maxwell. See New York Daily News, "Manhattan Federal Prosecutors Declined to Pursue Jeffrey Epstein and Ghislaine Maxwell Case in 2016: Sources" (Oct. 13, 2020), https://www.nvdail
o these matters. Sincerely, Is/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP New York, New York 10022 cc: Mark S. Cohen, Esq. Jeff Pagliuca, Esq. Laura Menninger, Esq. Bobbi C. Stemheim, Esq. EFTA00089617
k, New York 10022 cc: Mark S. Cohen, Esq. Jeff Pagliuca, Esq. Laura Menninger, Esq. Bobbi C. Stemheim,
dge Nathan: The Government respectfully submits this letter to bring to the Court's attention an opinion piece (the "Op-Ed") published yesterday in the New York Daily News, which was authored by David Markus, Esq., who represents the defendant in connection with this case. Mr. Markus's statements in the Op-Ed were in
l: (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 Markus, Esq. (by email) EFTA00098451
(by ECF) Laura Menninger, Esq. (by ECF) Jeffrey Pagliuca, Esq. (by ECF) David Markus, Esq. (by email) EF
Entities connected to both New York Daily News and Jeffrey Pagliuca

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSONLaura Menninger
PERSON
Michael Cohen
PERSON
Prince Andrew
PERSON
Denver
LOCATIONSouthern District
LOCATION
Christian Everdell
PERSON
Colorado
LOCATIONCohen & Gresser LLP
ORGANIZATION
Department of Justice
ORGANIZATION
United States
LOCATION
Virginia Giuffre
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
Bill Clinton
PERSONBates
PERSON
Alan Dershowitz
PERSON
Stephen Hawking
PERSONLeon Black
PERSON