Epstein Secrets

ll written and oral communications between the government and the attorneys for these individuals — including , but not limited to, Bradley Edwards, David Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and Jack Scarola (the "Attorneys") — concerning or relating to Mr.

ing , but not limited to, Bradley Edwards, David Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinge

ER 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

ll written and oral communications between the government and the attorneys for these individuals — including , but not limited to, Bradley Edwards, David Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and Jack Scarola (the "Attorneys") — concerning or relating to Mr.

ing , but not limited to, Bradley Edwards, David Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinge

l 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

ll written and oral communications between the government and the attorneys for these individuals — including , but not limited to, Bradley Edwards, David Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and Jack Scarola (the "Attorneys") — concerning or relating to Mr.

ing , but not limited to, Bradley Edwards, David Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinge

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

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."13 "We have her dead to rights," he said.14 This Court cannot accept without

t foment the Government's investigation. Moreover, the Assistant United States Attorney has represented to this Court that he has no idea what is in Boies Schiller's files, and that for all he knows every witness who was deposed stood on his/her Fifth Amendment rights and refused to answer questions.

REMAN P.C. 150 East 10th Avenue Denver, CO 80203 Phone: Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: Attorneys for Ghislaine Maxwell 28 EFTA00077603 C

; the law firm had provided that information well before the investigation began. The government did indeed have previous contact with the firm. And Boies Schiller was instrumental in fomenting the Maxwell prosecution. The record is surpassingly clear: But for the government's misrepresentation, witti

, AUSA met with attorneys from Boies Schiller, who "urged 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."

. 150 East 10th Avenue Denverile. Phone: Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York NY 10011 Phone: Attorneys for Ghislaine Maxwell EFTA00086658 TABLE

ing , but not limited to, Bradley Edwards, David Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinge

ll written and oral communications between the government and the attorneys for these individuals — including , but not limited to, Bradley Edwards, David Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and Jack Scarola (the "Attorneys") — concerning or relating to Mr.

l 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

ll written and oral communications between the government and the attorneys for these individuals — including , but not limited to, Bradley Edwards, David Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and Jack Scarola (the "Attorneys") — concerning or relating to Mr.

ing , but not limited to, Bradley Edwards, David Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinge

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

explain this in more detail. Maxwell Pre-Trial Mot. Nos. 4 8c 5. But the point is this: The defamation case should have been extremely narrow, but Boies Schiller transformed it into something much broader—a proxy prosecution of Epstein and Maxwell for allegedly trafficking and abusing which then co

ns," Reply ISO Mot. to Suppress, Ex. J, p 8, and David Boies later complained about his frustration that the g

MISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Christian R. Everdell COHEN & GRESSER LLP Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Phone: Attorneys for Ghislaine Maxwell EFTA00097331 TABLE OF CONTENTS TABLE OF CONTENTS ii TABLE OF AUTHORI

t, apart from issuing a subpoena to the law firm Boies, Schiller and Flexner, which represents a number

l COHEN & GRESSER LLP New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Denver, CO 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim New York, NY 10011 Phone: Attorneys for Ghislaine Maxwell EFTA00094289 TABLE OF CONTENTS Page PRELIMINARY S