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Southern District of New York I St. Andrew's Plaza New York, NY 10007 Haddon, Morgan and Foreman, P.0 Jeffrey S. Pagliuca 150 Eost lath Avenue Denver, Co PH FX www hmflaw corn Re: United States v. Ghisiaine Maxwell, 20 Cr. 330 (AJN) Defendant's Good Faith, Non-Frivolous Objections to Proffere
annot have been made either in the course of or in furtherance of any conspiracy at issue here and are no more than "idle chatter." United States v. Lieberman, 637 F.2d 95, 102 (2d Cir.1980) (challenged testimony "smack[ed] of nothing more than casual conversation about past events. It is difficult to env
tatute 'on its face' does not in itself justify an injunc- EFTA00191804 STOLT-NIELSEN, SA. U.S. 185 Clicas442 Pad 177 Pratte. Circuit noted in Denver, in the absence of a chilling effect on constitutional rights, the adversary system "afford(s) defen- dants, after indictment, a federal forum in
teenth Amendment, People of State of New EFTA00191873 UNITED STATES I OUSTER CHANNEL WINO CORPORATION cut so 370 F.34 475 (1$47) I York ex rel. Lieberman Van De Carr, 199 U.S. 662, 26 S. 1 144, 60 UNITED STATES of America, L.Ed. 305 (1905); and that ordi- Appellee, nances validly prohibiting the
le that made it 5-all. He earlier hit his 41st home run, matching him with Boston's David Ortiz fur the major league lead. Cubs 8, Rockies 7 In Denver, pinch-hitter Ryan Theriot hit a three- run double in the eighth in- ning and the Cubs over- came 10 walks to snap a four-game losing streak. Marl
victory of anti-war political novice Ned Lamont over three-term incum- bent Sen. Joe Lieberman. D-Corm.. in last week's Democratic primary — Sen. Lieberman had remained a staunch defender of the war — to portray the Democrats as America- hating wimps. With so many in- cumbents struggling to distance
Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Haddon Morgan and Foreman, P.0 Jeffrey S. Pagliuca 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmtlaw.com jpagliuccahmtlaw.com Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) D
Page: EFTA00014982 →annot have been made either in the course of or in furtherance of any conspiracy at issue here and are no more than "idle chatter." United States v. Lieberman, 637 F.2d 95, 102 (2d Cir.1980) (challenged testimony "smack[ed] of nothing more than casual conversation about past events. It is difficult to env
Page: EFTA00014983 →Entities connected to both Denver and Lieberman

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Colorado
LOCATION
Prince Andrew
PERSON
Michael Cohen
PERSONJeffrey Pagliuca
PERSON
Donald Trump
PERSONLeon Black
PERSON
Marc Rich
PERSON
George W. Bush
PERSON
Department of Justice
ORGANIZATION
United States
LOCATIONMartin Weinberg
PERSON
Virginia Giuffre
PERSON
Julie K. Brown
PERSON
Prince Charles
PERSONBerger
PERSON
Michael Jackson
PERSON
Atlanta
LOCATION
Credit Suisse
ORGANIZATION