Epstein Secrets

TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi . Stemheim Attorneys for Chislaine Maxwell EFTA00029816 --- PAGE BREAK --- TABLE OF CONTENTS TABLE OF

Judge McMahon that the prosecutors had no idea what was in Boies Schiller's file. Indeed, he insisted, there had been no contact whatsoever between Boies Schiller and United States Attorney's Office before the government commenced its investigation. Nor, said the prosecutor, did Boies Schiller have a

met with attorneys from Boies Schiller, who "urged Kramer to open an investigation of" Epstein and Maxwell!' Then, after Maxwell's two depositions, David Boies himself apparently approached the government in the summer of 2016, asking "if the Southern District would consider charging Maxwell with perjury."

en AUSA appeared before Judge McMahon barely four months later, however, he told her none of this, unequivocally and falsely disavowing any role by Boies Schiller in fomenting the investigation and denying any contacts between Boies Schiller and his office before November 2018. Even though AUSA had

y prosecution after a second meeting with attorneys, which took place after at least one of Maxwell's depositions. As reported in the Daily News, "David [Boles] was particularly frustrated by the failure to pursue a perjury charge.s13 "We have her dead to rights," he said.14 This Court cannot accept without

029131 --- PAGE BREAK --- Respectfully submitted, s/ Jeffrey S. Pagliuca Jeffrey S. Pagliuca Laura A. Menninger Christian R. Everdell COHEN & GRESSER LLP EMAN P.C. Bobbi C. Stemheim Attorneys for Ghislaine Maxwell 28 EFTA00029132 --- PAGE BREAK --- Certificate of Service I hereby certify that

idence Obtained from the Government's Subpoena to Boies Schiller and to Dismiss Counts Five and Six 4.

us with any questions. Your consideration is greatly appreciated. Respectfully submitted, Is/ Christian R. Everdell Christian R. Everdell COHEN & GRESSER LLP MEN cc: All counsel of record (via email) I For documents that the government has designated as "Confidential," we have preliminarily indicated t