[Contractor
Summary
From: To: [Contractor (USANYS) [Contractor]" ' (USANYS) (USANYS) [Contractor]" Cc: a)" <Winlan .› . " (USANYS)" Subject: RE: Follow Up Date: Mon, 03 May 2021 01:03:21 +0000 Attachments: 2021.05.03_Discovery_Production.zip: 2021.05.03_Maxwell_Discovery_Letter.docx Inline-Images: image001.png Of course, attached—sorry for assuming! From: Sent: Sunday, May 2, 20219:00 PM To: (USANYS) [Contractor] < <a; (USANYS) [Contractor] <a Cc: (USANYS) < >; (USANYS) [Contractor] Subject: RE: Follow Up >*, Thanks! Would you mind dating them for tomorrow, please? I want to just confirm with the team and the chiefs that we are good with the plan to produce these before I send them out. From: (USANYS) (Contractor] Sent: Sunday, May 2, 20218:59 PM To: >; (USANYS) [Contractor] <1 Cc: <a; (USANYS) < Subject: RE: Follow Up Updated cover letter and zipped production attached (both dated for today). From: Sent: Sunday, May 2, 20218:44 PM To: (USANYS) [Contractor] <
Persons Referenced (3)
“...overy to Maxwell? All should be marked CONFIDENTIAL. Thanks very much, From: Sigrid McCawley Sent: Wednesday, April 28, 2021 3:32 PM To: (usANys)< > Cc: Sigrid McCawley...”
Defense Counsel“...mail, would you mind putting the production into a zip file for me to email to defense counsel, please? EFTA00085222 From: Sent: Sunday, May 2, 2021 8:42 PM To: (USANYS)...”
United States“...copy was provided to . It is noted that the receipts were dated based on the United States Eastern Standard Time Zone date. The photographs, certification and original E...”
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EFTA DisclosureRelated Documents (6)
Case 1:15-cv-07433-LAP Document 1078-1 Filed 07/29/20 Page 1 of 8
Case 1:15-cv-07433-LAP Document 1078-1 Filed 07/29/20 Page 1 of 8 EXHIBIT A EFTA00094765 C aSaSe115213mtlitnal3a4C3NDdamtrnewarlICITE-FilEdal7027YEE02 CP age*cif at 8 IIADDON M O R G A N FOREMAN July 21, 2020 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Haddon, Morgan and Foreman, t.c Jeffrey PagHue° 150 East 10th Avenue Denver, Colorado 80203 mi 303.831.7364 FX 303.832.2628 www.hmflaw.com jpaglucaahmflaw.com Re: United States v. Ghislaine Maxwell, Case No. 20 Cr. 330 (MN), Local Criminal Rule 23.1 Dear Judge Nathan, On behalf of our client, Ghislaine Maxwell, we write to request that the Court enter an order prohibiting the Government, its agents and counsel for witnesses from making extrajudicial statements concerning this case. Although Ms. Maxwell is presumed innocent, the Government, its agents, witnesses and their lawyers have made, and continue to make, statements pr
Case 20-2413. Document 10-1, 07/30/2020, 2896538, Pagel of 38
Case 20-2413. Document 10-1, 07/30/2020, 2896538, Pagel of 38 UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT Thurgood Marshall U.S. Courthouse 40 Foley Square, New York, NY 10007 Telephone: MOTION INFORMATION STATEMENT Docket Number(s): 20-2413 Caption [use short till Motion for. Emergency Motion to Stay Pending Appeal Set forth below precise, compkte statement of relief sought: Ms. Maxwell seeks a stay pending appeal, or in the alternative, a temporary administrative stay to afford this Court sufficient time to consider on the merits the motion to stay pending appeal v. Maxwell MOVING PARTY: Defendant-Appellant Ghislaine Maxwell OPPOSING PARTY: Plaintiff-Appellee 9PlaintifT attendant EiAppellant/Petkioner DAppellet/Respondent MOVING ATTORNEY: Adam Mueller [name of attorney, with fon, address, phone number and e-mail) Haddon, Morgan and Foreman, P.C. Boies Schiller & Flexner LLP OPPOSING ATTORNEY: Sigrid McCawley Court- Judge/ Agency appealed from: Hon.
Case 20-2413. Document 40. 08'20/2020. 2913550, Pagel of 74
Case 20-2413. Document 40. 08'20/2020. 2913550, Pagel of 74 20-2413 United States Court of Appeals for the Second Circuit Plaintlff-Appelke, —against— GHISLA1NE MAXWELL, Defendant-Appellant, SHARON CHURCHER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, ALAN M. DERSHOWITZ, MICHAEL CERNOVICH, DBA CERNOVICH MEDIA Intervenors. ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK, 15-CV-7433 (LAP) Ghislaine Maxwell's Opening Brief Ty Gee Adam Mueller HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Den r 2 Tel. Attorneys for Defendant-Appellant Ghislaine Maxwell EFTA00075477 Case 20-2413, Document 40, 08/20/2020, 2913550, Page2 of 74 Table of Contents Table of Authorities iii Introduction 1 Jurisdictional Statement 2 Issues Presented 3 Statement of the Case and the Facts 3 The defamation action and the Protective Order 3 The motion to unseal and the first appeal 6 The remand, the arrest,
Dershowitz, 410 F.Supp.3d 564 (2019)
Dershowitz, 410 F.Supp.3d 564 (2019) derives from their inherent power to preserve adversary process's integrity. KeyCite Yellow Flag - Negative Treatment Distinguished by Penrose Hill, Limited v. Mabmy, N.D.Cal., August 18, 2020 410 F.Supp.3d 564 United States District Court, S.D. New York. Plaintiff, v. Alan DERSHOWITZ, Defendant. 19 Civ. 3377 (LAP) 10/16/2019 Synopsis Background: Plaintiff brought action alleging that defendant defamed her by making public statements that she was liar, had committed perjury, and was conspiring with law firm to extort him and others by claiming that she was forced to engage in sexual activity with him. Defendant moved to dismiss and to disqualify law firm Holdings: The District Court, Loretta A. Preska, Senior District Judge, held that: III single publication rule did not apply to bar claim on limitations grounds; (2) plaintiffs allegations were sufficient to defeat defendant's claim to qualified self-defense privilege; and
Subject: FW: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB)
From: To: Subject: FW: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Date: Mon, 26 Aug 2019 20:10:39 +0000 From: Sent: Monday, August 26, 2019 3:47 PM To: Cc: Subject: FW: United States v. Jeffrey Epstein, 19 Cr. 490 (FMB) From: Sent: Monday, August 26, 2019 1:58 PM To: Cc: Subject: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Judge Berman, We received a request from the Court for the contact information for victim attorneys. Not all victims are represented by counsel, but the attorneys we are aware of are: • Brad Edwards • Stan Pottinger • Gloria Allred • Sigrid McCawley • Alex Conlon • Bob losefsberg • Kimberly Lerne • Ten Gibbs Although the Government has made best efforts to notify victims of tomorrow's proceeding, the Government does not know which victims plan to attend tomorrow's conference, and it is possible that victims the Government is not aware of may attend. We have not copied defense counsel here, in order to respect t
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (MN) REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER MOTION UNDER THE DUE PROCESS CLAUSE TO SUPPRESS ALL EVIDENCE OBTAINED FROM THE GOVERNMENT'S SUBPOENA TO BOLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, CO 80203 Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Attorneys for Ghislaine Maxwell EFTA00077571 Table of Contents Table of Contents Table of Authorities ii Table of Exhibits iv Introduction and Summary of the Argument 1 I. The Facts 2 II. The Government's Response to Maxwell's Motion. 6 A. The Government's Defenses Are Not Credible. 7 B. Assuming the Government's De
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