rn District of New York 1 St. Plaza New York, NY 10007 From: Laura Mennmgerl Sent: Thursday, August 26, 2021 10:55 AM To: (USANYS) Cc: .: >; Jeff Pagliuca (USANYS) [Contractor] EFTA00075624 (USANYS) [Contractor] < Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] T

to work off of during this review? Thank you, Laura From: (USANYS) Sent: Wednesday, August 25, 2021 1:23 PM To: Laura Menninger l< Cc: )< ;Jeff Pagliuca [Contrac or >; on rac or > Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Laura, The items are available f

been de-designated, our office will produce them to you. Best, From: Laura Menninger Sent: Friday, May 7, 2021 4:43 PM To: Cc: (USANYS) I c ; Jeff Pagliuc 'Bobbi Sternhei Subject: RE: US v. Maxwell - [conferral re photo and other discovery deficiencies] Thank you for your response of April 23. I haven't

From: To: Jeff Pagliuc Cc: Nicole Simmons Subject: RE: Maxwell Date: Mon, 15 Jul 2019 20:18:39 +0000 Importance: Normal Jeff, We haven't spoken to Mark and hadn't heard f

Please let us know if it would be useful to chat in the interim—we're happy to, if so—and we look forward to being in touch soon. thank you, From: Jeff Pagliuca Sent: Tuesday, July 09, 2019 18:56 To: Cc: Nicole Simmons Subject: RE: Maxwell EFTA00083886 Hello, I expect you all have been busy in the las

o discuss a potential proffer metting during our next call which I think is scheduled for 7-11 at 4pm my time. Best Regards, Jeff <image001.jpg> Jeffrey S. Pagliuca Haddon, Morgan and Foreman, P.C. ISO East 10th Avenue Denver, Colorado 80203 Main 303.831.7364 FX 303.832.2628 www. m aw.com CONFIDENTIALITY NO

ts: letter_to_USA_re_protective_order (002)_(002)final.pdf Inline-Images: image001.jpg FYI — we'll circle up on this when is back tomorrow. From: Jeff Pagliuca Sent: Sunday, August 09, 2020 18:56 To: Cc: Laura Mennin er ;I >; Christian Everdell ; Nicole Simmons < Subject: Letter regarding discovery at

>; Christian Everdell ; Nicole Simmons < Subject: Letter regarding discovery attached. Dear Counsel, Please see attached conferral letter. Jeff Jeffrey S. Paglluca Haddon. Moreau and Foreman, P.C. www.hmflaw.com <->; ; Mark S. Cohen mation that is confidential or legally privileged. If you are not the inten

le up on this when is back tomorrow. From: Jeff Pagliuca Sent: Sunday, August 09, 2020 18:56 To: Cc: La

Fromi To: Cc: Jeff Pagliuca cipae,huca(tclunllaw.com>, Laura Memunger Klmennme,er(alimflaw.corn.?. bestentheim_mae.com <besternheirn(iipnac.com> Subject: [EXTERNAL] FW: Activi

avid Boies, II [email protected] NYC Managing [email protected] Patrick J. Smith patrick.smith@smithvillazoccom suzanne.kowalski@smithvillazoccom Jeffrey S. Pagliuca [email protected] [email protected] Laura A. Menninger [email protected] [email protected] [email protected] [email protected] Bobb

Fromi To: Cc: Jeff Pagliuca cipae,huca(tclunllaw.com>, Laura Memunger Klmennm

addresses receive invitations to the video conference. • • • • • Best, From: Christian Everdell • Sent: Thursday, July 2, 20201:14 PM To: 'Jeff Pagliuca' Cc: Subject: RE: SDNY indictment ; Mark S. Cohen < >; Laura Menninger Mark and I would also like to listen in. As we mentioned, we will not be a

Subject: RE: SDNY indictment Please add Jeff ); Christian Everdell; Mark S. Cohen; Laura Menninger and to the list. Thank you, EFTA00084307 Jeffrey S. Pagliuca Haddon, Morgan and Foreman, P.C. mation that is confidential or legally privileged. If you are not the intended recipient, or a person responsible

• Sent: Thursday, July 2, 20201:14 PM To: 'Jeff Pagliuca' Cc: Subject: RE: SDNY indictment ; Mark S. Co

m reading his email correctly, he's not available until 6 p.m. (our time; i.e., 4 p.m. his time), no? From: Sent: Sunday, July 07, 2019 15:46 To: 'Jeff Pagliuca' Cc: Nicole Simmons < Subject: RE: Maxwell Jeff, Thanks for speaking with me this afternoon. I've copied my colleagues, have everyone's contact i

times be difficult so If it is not an inconvenience perhaps you could email the indictment along with the subpoena and waiver. Best Regards, Jeff Jeffrey S. Pagliuca Haddon, Morgan and Foreman, P.C. Main www.hmflaw.com CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mai

om: Sent: Sunday, July 07, 2019 15:46 To: 'Jeff Pagliuca' Cc: Nicole Simmons < Subject: RE: Maxwell Jef

: [EXTERNAL] RE: Subpoena fo Date: Sat, 20 Nov 2021 19:44:11 +0000 Attachments: 2021.11.15_-_ 1 - Letter from Patrick J. Smith to Judge_Nathan.pdf Jeff Pagliuca Inline-Images: image001.gif; image002.jpg Counsel - We are required to file our Nov. 15 letter to Judge Nathan on the public docket by tomorrow (co

der, and the motion contains information designated as confidential. Accordingly, we will defer to it as to what you should receive. Best Regards, Jeffrey S. Pagliuca. On Nov 17, 2021, at 7:58 PM, Brian Burns wrote: Defense counsel — Would you please provide us a copy of your motion seeking the issuance of this

r from Patrick J. Smith to Judge_Nathan.pdf Jeff Pagliuca Inline-Images: image001.gif; image002.jpg Couns

Defts_Rule_17_Subs.pdf Inline-Images: image001.jpg From: Nicole Simmons Sent: Thursday, April 15, 2021 5:08 PM To: 'Nathan NYSD Chambers' • Cc: Jeff Pagliuca •c: :; Laura Me n ni nger 'Bobbi Sternheim >; <->; (USANYS) Subject: U.S. v. Maxwell, Case No. 20 Cr. 330 (AJN) [Resp to Govs April 5, 2021 re.

with the government regarding any proposed redactions and file the Response on the public docket as directed by the Court. Respectfully Submitted, Jeffrey S. Pagliuca Nicole Simmons Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 DIRECT: WWW hmf

1 5:08 PM To: 'Nathan NYSD Chambers' • Cc: Jeff Pagliuca •c: :; Laura Me n ni nger 'Bobbi Sternheim >;

o the Government's October 7, 2020 letter, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, Haddon, Morgan and Foreman, t.c Jeffrey FagIluca 150 East 10th Avenue Denver, Colorado 80203 EH 303.831.7364 FX 303.832.2628 www.hmflaw.com [email protected] At the initial conference in thi

the Court. It may be appropriate for the Court to schedule a status conference after November 9 to consider these issues. Respectfully Submitted, Jeff S. Pagliuca CC: Counsel of Record (via ECF) EFTA00076289

these issues. Respectfully Submitted, Jeff S. Pagliuca CC: Counsel of Record (via ECF) EFTA00076289

20, denying Ms. Maxwell's motion to reconsider. Dated: July 29, 2020. Respectfully submitted, s/ Laura A. Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) Ty Gee (pro hac vice) HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Ghislaine Maxwell 1 EFTA00076389 CasastrabiAZI71432)IaAini

Sorry. No. 6 Thanks very much. 7 MR. CASSELL: Thank you, your Honor. 8 THE COURT: Anything from the defense. 9 MR. PAGLIUCA: Yes, your Honor. Jeff Pagliuca on 10 behalf of Ms. Maxwell. 11 Your Honor, I have never opposed a pro hac motion in 12 my 34 years of practice, so this is a first for me. But

23 24 25 Case 20-2413, Document 44, 08/20/2020, 2913556, Page67 of 78 K7N9GIUD App.-0841 150. Declaration of Mister how does he say it, Mr. Pagliuca? Say it again. MS. MENNINGER: Pagliuca. THE COURT: Mr. Pagliuca in opposition to the motion to compel. Unseal. 150-1. Additional pages from Ms. M

From: '• To: Jeff Pagliuca Cc: "ceverdel C (USANYS)" Subject: RE: Subpoena for Date: Thu, 18 Nov 2021 02:27:03 +0000 Attachments: 2021.11.14 Mm forOrderAuthaSubPursm_to_F

der, and the motion contains information designated as confidential. Accordingly, we will defer to it as to what you should receive. Best Regards, Jeffrey S. Pagliuca. On Nov 17, 2021, at 7:58 PM, Brian Burns wrote: Defense counsel — Would you please provide us a copy of your motion seeking the issuance of this

From: '• To: Jeff Pagliuca Cc: "ceverdel C (USANYS)" Subject: RE: Subpoe

dant 22 Denver, Colorado 80203 BY: JEFFREY S. PAGLIUCA, ESQUIRE 23 LAURA A. MENNIGER, ESQUIRE 24 Als

BY: STAN POTTINGER, ESQUIRE 19 On Behalf of Defendant: 20 HADDON MORGAN FOREMAN 21 Attorneys for Defendant 22 Denver, Colorado 80203 BY: JEFFREY S. PAGLIUCA, ESQUIRE 23 LAURA A. MENNIGER, ESQUIRE 24 Also Present: 25 MAGNAO LEGAL SERVICES EFTA00083934 Confidential Page 3 1 2 THE VIDEOGRAPHER:

Pottinger, 6 also representing the plaintiff. 7 MR. CASSELL: Paul Cassell, from 8 Salt Lake City, Utah, also representing 9 10 MR. PAGLIUCA: Jeff Pagliuca and 11 Laura Menninger, on behalf of Ms. 12 Maxwell. 13 And Ms. McCawley has also entered 14 the room, and we have an assistant from 15 Boi

From: Nicole Simmons To: "F- ‹ Cc: Jeff Pagliuca Ann Lundbe Laura Menninger • rr Subject: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) [Proposed Redaction to Request and Reply to Modif

df; Ex._B_2020.08.24_,ISP_Reply_Ltrje._Modification_of the_Protective_Order.pdf Inline-Images: image00 1 jpg Dear Judge Nathan, At the request of Jeffrey S. Pagliuca, please see attached Ms. Maxwell's Proposed Redactions to her Request and Reply in Support of Modifying the Protective Order filed under. Regards,

From: Nicole Simmons To: "F- ‹ Cc: Jeff Pagliuca Ann Lundbe Laura Menninger • rr Subject: Uni

rther tomorrow. Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007 (212) 637-2225 From: Jeff Pagliuca <[email protected]> Sent: Sunday, July 7, 2019 3:09 PM To: < > Cc: Nicole Simmons <[email protected]> Subject: Maxwell Dear M, It was a p

times be difficult so If it is not an inconvenience perhaps you could email the indictment along with the subpoena and waiver. Best Regards, Jeff Jeffrey S. Pagliuca Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 Main 303.831.7364 FA 303.832.2628 JpaglIticagshmflaw.com www.hmfla

a New York, NY 10007 (212) 637-2225 From: Jeff Pagliuca <[email protected]> Sent: Sunday, July 7, 201

ne Maxwell, 20 Cr. 330 (AJN) (Request to Modify Protective Order (Under Seal)] From: Nicole Simmons Sent: Monday, August 17, 2020 8:01 PM To: Cc: Jeff Pagliuca Laura Menninger < > Ann Lundber Subject: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) [Request to Modify Protective Order (Under Seal)] De

ubject: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) [Request to Modify Protective Order (Under Seal)] Dear Judge Nathan, At the request of Jeffrey S. Pagliuca, please see attached Ms. Maxwell's Letter Motion, Affidavit, and accompanying exhibits filed under seal today August 17, 2020. Regards, Nicole Ni

t: Monday, August 17, 2020 8:01 PM To: Cc: Jeff Pagliuca Laura Menninger < > Ann Lundber Subject: United

, and SDNY prosecutors September 10 - 11 Everdell and SDNY prosecutors Phone Calls October 2 Everdell and SDNY prosecutors Cohen, Everdell, Pagliuca, and SDNY prosecutors meet at SDNY offices Emafls Meetings Cohen, Everdell, and SDNY prosecutors Cohen, Everdell, and SDNY prosecutors 2

ecutors t o August 15 Cohen, Everdell and SDNY prosecutors r September 3-5 Everdell and SDNY prosecutors t o September 5 Cohen, Everdell, Pagliuca, and SDNY prosecutors September 10 - 11 Everdell and SDNY prosecutors Phone Calls October 2 Everdell and SDNY prosecutors Cohen, Everdell,

Timeline of Discussions with SDNY Prosecutors EFTA00011185 --- PAGE BREAK --- Maxwell's Attorneys Were In Regular Contact With SDNY Prosecutors Pagliuca and SDNY prosecutors Pagliuca and SDNY prosecutors t o July 15 Everdell and SDNY prosecutors July 15 - 16 Everdell and SDNY prosecutors Co

o the Government's October 7, 2020 letter, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, Haddon, Morgan and Foreman, t.c Jeffrey FagIluca 150 East 10th Avenue Denver, Colorado 80203 EH 303.831.7364 FX 303.832.2628 www.hmflaw.com [email protected] At the initial conference in thi

the Court. It may be appropriate for the Court to schedule a status conference after November 9 to consider these issues. Respectfully Submitted, Jeff S. Pagliuca CC: Counsel of Record (via ECF) EFTA00066552

these issues. Respectfully Submitted, Jeff S. Pagliuca CC: Counsel of Record (via ECF) EFTA00066552

6:42 +0000 Importance: Normal Inline-Images: image004.jpg; image001.jpg Is this call at 4 happening, or have we heard from her new counsel? From: Jeff Pagliuca Sent: Tuesday, July 9, 2019 6:56 PM To: Cc: Nicole Simmons Subject: RE: Maxwell Hello, I expect you all have been busy in the last few days. Wh

e in a position to discuss a potential proffer mating during our next call which I think is scheduled for 7-11 at 4pm my time. Best Regards, Jeff Jeffrey S. Pagliuca Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 www.hmflaw.com CONFIDENTIALITY NOTICE: This e-mail transmission, an

r have we heard from her new counsel? From: Jeff Pagliuca Sent: Tuesday, July 9, 2019 6:56 PM To: Cc: Ni

o the Government's October 7, 2020 letter, United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan, Haddon, Morgan and Foreman, t.c Jeffrey FagIluca 150 East 10th Avenue Denver, Colorado 80203 EH 303.831.7364 FX 303.832.2628 www.hmflaw.com [email protected] At the initial conference in thi

the Court. It may be appropriate for the Court to schedule a status conference after November 9 to consider these issues. Respectfully Submitted, Jeff S. Pagliuca CC: Counsel of Record (via ECF) EFTA00081943

these issues. Respectfully Submitted, Jeff S. Pagliuca CC: Counsel of Record (via ECF) EFTA00081943

From: "- To: Jeff Pagliuca Cc: Nicole Simmons Subject: RE: Maxwell Date: Tue, 09 Jul 2019 23:38:05 +0000 Importance: Normal Attachments: blanlcproffer_agreement.pdf Inlin

in a position to discuss a potential proffer metting during our next call which I think is scheduled for 7-11 at 4pm my time. Best Regards, Jeff Jeffrey S. Pagliuca Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue Denver, Colorado 80203 www.hmflaw.com EFTA00096137 CONFIDENTIALITY NOTICE: This e-mail t

From: "- To: Jeff Pagliuca Cc: Nicole Simmons Subject: RE: Maxwell Date: