Epstein Secrets

b. An estate in Palm Beach, Florida owned by Epstein (the "Palm Beach Residence"), which is depicted in the following photograph: c. A ranch in Santa Fe, New Mexico owned by Epstein (the "New Mexico Residence"), which is depicted in the following photograph: 6 EFTA00075080 cadiattelaW414§§1Weria

epasinEaft,40=230,4ffientDdlignitiaffiatalelitheffffefilagtegtataf 8 The Honorable Alison J. Nathan July 21, 2020 Page 7 Respectfully Submitted, Jeffrey S. Pagliuca cc: U.S. Attorney's Office for the Southern District of New York Mark Cohen Christian Everdell Cohen & Gresser LLP Laura A. Menninger Haddon,

ederal prosecutor's office in the Southern District of New York. "In some cases, Maxwell participated in the abuse herself." A lawyer for Maxwell, Jeff Pagliuca, did not immediately respond to messages seeking comment. David Boies, who along with Sigrid McCawley represents a dozen of Epstein's accusers, sa

2020 Page 7 Respectfully Submitted, Jeffrey S. Pagliuca cc: U.S. Attorney's Office for the Southern Dis

at a number of Epstein's luxurious homes, including his sprawling Upper East Side townhouse in Manhattan, an estate in Palm Beach, Fla., a ranch in Santa Fe, N.M., and Maxwell's home in London, according to the charges. "Minor Victim-2," according to the indictment, was under 18 when she was flown to N

ederal prosecutor's office in the Southern District of New York. "In some cases, Maxwell participated in the abuse herself." A lawyer for Maxwell, Jeff Pagliuca, did not immediately respond to messages seeking comment. David Boies, who along with Sigrid McCawley represents a dozen of Epstein's accusers, sa

on' by law enforcement, Cohen claimed her phone had been hacked and she had to preserve the phone as evidence. MAXWELL'S LEGAL TEAM: Pictured l-r: Jeffrey S. Pagliuca,Christian R Everdell, Laura A. Menninger and Mark Cohen. In their filings to the court Maxwell's lawyers had argued that she is at increased risk o

the abuse herself." A lawyer for Maxwell, Jeff Pagliuca, did not immediately respond to messages seeking

212-1 (filed July 19, 2013) ("SDFL Privilege Log"), at 4, 5, 7. Moreover, 1I EFTA00066004 discovery demonstrates that the FBI's field offices in Santa Fe, New Mexico, and St. Thomas, Virgin Islands were contacted for assistance in the investigation. Exh. G (12/6/06 redacted FBI request). As the NPA

PORT 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 Maxwell EFTA0006598

tian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C

room, which will allow for appropriate social distancing between [Mr. Robertson] and his lawyers." Id. Second, the government represents that "the Santa Fe jail is willing to provide an exception to the policy barring in-person attorney visits, and will work to accommodate in-person visits between Rober

3 West 19th Street - 4th Floor New York, NY 10011 Phone: 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, Colorado 80203 Phone: Attorneys for Ghislaine Maxwell EFTA000933

rd Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C

anch? A. Typically, depending upon what aircraft he selected, if we were flying the Gulfstream, which is a smaller, lighter aircraft, we would use Santa Fe, New Mexico Airport. And if we were flying the Boeing, which is a large airliner, we would fly into Albuquerque due to weight restrictions. Q. I'd

ates Attorney for the Southern District of New York BY: Assistant United States Attorneys HADDON MORGAN AND FOREMAN Attorneys for Defendant BY: JEFFREY S. PAGLIUCA CHRISTIAN R. EVERDELL LAURA A. MENNINGER -and- BOBBI C. STERNHEIM -and- RENATO STABILE Also Present: District Judge , FBI NYPD Sunny Dresche

would not make sense to return for one day of that week. So, really, it would be a 10-day break in the trial. I don't think that makes sense, Mr. Pagliuca. I know I mentioned that, but I'm not sure I had that fully in mind at the time, and that's practically what we would be talking about. MR. PAGLIU