Epstein Secrets

2011) 5 United States v. Cohn, 230 F. Supp. 587 (S.D.N.Y. 1964) 4 United States v. Cunningham, 672 F.2d 1064 (2d Cir. 1982) 10 United States v. Gotti, 771 F. Supp. 552 (E.D.N.Y. 1991) 10 United States v. Halper, 590 F.2d 422 (2d Cir. 1978) 6 United States v. Harris, 805 F. Supp. 166 (S.D.N.Y. 1

EMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION FOR A SEVERANCE OF AND SEPARATE TRIAL ON COUNTS FIVE AND SIX OF THE SUPERSEDING INDICTMENT Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Phone: Christian R. Everdell COHEN & DRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi C. St

AND SIX OF THE SUPERSEDING INDICTMENT Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C

2011) 5 United States v. Cohn, 230 F. Supp. 587 (S.D.N.Y. 1964) 4 United States v. Cunningham, 672 F.2d 1064 (2d Cir. 1982) 10 United States v. Gotti, 771 F. Supp. 552 (E.D.N.Y. 1991) 10 United States v. Halper, 590 F.2d 422 (2d Cir. 1978) 6 United States v. Harris, 805 F. Supp. 166 (S.D.N.Y. 1

EMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION FOR A SEVERANCE OF AND SEPARATE TRIAL ON COUNTS FIVE AND SIX OF THE SUPERSEDING INDICTMENT Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Phone: Christian R. Everdell COHEN & DRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi C. St

AND SIX OF THE SUPERSEDING INDICTMENT Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C

ement is being introduced on behalf of, or against, 17 knows about the statement. So when you look at their papers, 18 they cite United States v. Gotti for the proposition that it 19 goes to state of mind. Well, you know who Mr. Gotti is, and 20 Mr. Gotti was charged with witness tampering. Mr. G

d 21 to introduce some wiretapped statements that the FBI had, where 22 he was talking to an informant and telling the informant things 23 that Gotti said went to his state of mind. Well, the Second 24 Circuit said, yes, you can do that, Mr. Gotti, first of all, 25 because the government's intr

ly, your Honor, I think you can 10 just see from the upset there what's going to be happening at 11 this trial. This is the direct quote from Mr. Pagliuca. 12 "Fantastical conspiracy". That's going to be the argument from 13 the other side. They're obviously entitled to advance that 14 argument. B

ement is being introduced on behalf of, or against, 17 knows about the statement. So when you look at their papers, 18 they cite United States v. Gotti for the proposition that it 19 goes to state of mind. Well, you know who Mr. Gotti is, and 20 Mr. Gotti was charged with witness tampering. Mr. G

d 21 to introduce some wiretapped statements that the FBI had, where 22 he was talking to an informant and telling the informant things 23 that Gotti said went to his state of mind. Well, the Second 2.1 Circuit said, yes, you can do that, Mr. Gotti, first of all, 25 because the government's int

ly, your Honor, I think you can 10 just see from the upset there what's going to be happening at 11 this trial. This is the direct quote from Mr. Pagliuca. 12 "Fantastical conspiracy". That's going to be the argument from 13 the other side. They're obviously entitled to advance that 14 argument. B

the statement is being introduced on behalf of, or against, knows about the statement. So when you look at their papers, they cite United States v. Gotti for the proposition that it goes to state of mind. Well, you know who Mr. Gotti is, and Mr. Gotti was charged with witness tampering. Mr. Gotti want

Gotti wanted to introduce some wiretapped statements that the FBI had, where he was talking to an informant and telling the informant things that Gotti said went to his state of mind. Well, the Second Circuit said, yes, you can do that, Mr. Gotti, first of all, because the government's introducing

: In reply, your Honor, I think you can just see from the upset there what's going to be happening at this trial. This is the direct quote from Mr. Pagliuca. "Fantastical conspiracy". That's going to be the argument from the other side. They're obviously entitled to advance that argument. But that's wh