Epstein Secrets

GARVY,ROBERT GELICKMAN,DONALD COOPER,J P POHLMANN,BURT ROOSEVELT,WILLIAM

Y,TALBOTT B ROBERTSON JR,HARRISON M FORMAN,MARCIA L VANHELLEMONT,ROBERT W KAPN

ed by authorized representatives of the Office cannot and do not constitute a "formal offer" or a "plea offer," as those terms are used in Lafler v. Cooper, 132 S.Ct. 1376 (2012); Missouri v. Frye, 132 S.Ct. 1399 (2012). 06.20.2018 EFTA00040594 Page 3 Bates Start Bates End Confidential Non-PDF Fi

By Email & Hand Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon. Morgan and Foreman, P.C. August 5, 2020 Re: United States v. Chislaine Maxwell, 20 Cr. 330 (MN) Dear Counsel: This letter provides discovery pursuant to Rule 16(a)

orneys after learning that her successor counsel, Cooper & Kirk, had received from her former counsel, Bo

nt/Petkioner DAppellet/Respondent MOVING ATTORNEY: Adam Mueller [name of attorney, with fon, address, phone number and e-mail) Haddon, Morgan and Foreman, P.C. Boies Schiller & Flexner LLP OPPOSING ATTORNEY: Sigrid McCawley Court- Judge/ Agency appealed from: Hon. Loretta A. Preska, District Judge

ed" to learn that plaintiff's successor counsel, Cooper & Kirk, had received from plaintiff's former coun

0 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, r.0 Ty Gee 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 HI 303.832.2628 www.hmtlaw.com [email protected] Re: Reconsideration of

ed by authorized representatives of the Office cannot and do not constitute a "formal offer" or a "plea offer," as those terms are used in Lafler v. Cooper, 132 S.Ct. 1376 (2012); Missouri v. Frye, 132 S.Ct. 1399 (2012). 0620.2018 EFTA00099136 Page 3 Bates Start Bates End Confidential Non-PDF Fil

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, CO 80203 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: This letter provides discov

ed" to learn that plaintiff's successor counsel, Cooper & Kirk, had received from plaintiff's former coun

0 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, P C Ty Gee 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 HI 303.832.2628 www.hmllaw.com [email protected] Re: Reconsideration of