Epstein Secrets

publicly filed). Please let me know what you think. If you agree that no redactions are needed, I'll email them to let them know. Thanks, ■ From: Nicole Simmons < Sent: Thursday, April 1, 20217:29 PM To: 'Nathan NYSD Chambers' < MI> Cc: Laura Menninger <M I>; Jeff Pagliuca Ma'; >; 'c >; (USANYS) ‹ > S

attention to page 5 of the joint letter, in which Menninger wrote: Indeed, this Court rejected Ms. Maxwell's argument that certain portions of the Response and its exhibits should be unredacted because the material had already been made public. See Dkt. No. 168 at 2-3; Letter Motion of Laura A. Menning

L 33301 Paul G. Cassell 383 S. University Street Salt Lake City. UT 84112 J. Stanley Pottinger 49 Twin Lakes Rd. South Salem m i NY 105 0 Is/ Nicole Simmons Nicole Simmons 7 EFTA00617185

say without applicable exceptions, or based on other evidentiary grounds. Those issues will be argued at the appropriate time. For purposes of this Response, Ms. Maxwell simply notes the fundamental errors in the Notice, failure to comply with the rules, and general principles that make the residual hea

le, FL 33301 Paul G. Cassell 383 S. University Street Salt Lake City UT 84112 J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 Is/ Nicole Simmons Nicole Simmons 13 EFTA00618146

irm that that his communications with Plaintiff regarding "media issues" were primarily for the purpose of providing legal advice. According to the Response "Ms. received legal advice from Mr. Pottinger regarding how to handle media inquiries in such a way as to not jeopardize her position in ongoing li

F system which will send notification of such filing to the following: U.S. Attorney's Office, SDNY One Saint Andrew's Plaza New York NY 10007 s/ Nicole Simmons 46 EFTA00090772

constitutes an impermissible constructive amendment and variance to the Indictment. Finally, what is clear from the government's proffer in their Response, the anticipated testimony o will serve as an improper constructive 13 EFTA00090739 amendment to, and an impermissible variance of, the Indictm