From: Sigrid McCawley
Summary
From: Sigrid McCawley To: Subject: Follow Up Date: Mon, 27 Apr 2020 15:34:48 +0000 Hello MI— below are the links for all the videos we have — missing because that video was taken by Menninger's reporter. Let me know if you have any trouble accessing these. Best, Sigrid BSF SUPPLEMENTAL RESPONSE TO GRAND JURY SUBPOENA Guiffre v. Maxwell, 15 Civ. 7433 (RWS), S.D.N.Y. In Re: Grand Jury Subpoena, Sealed Order, 19 Misc. 149 (Apr. 9, 2019) Video Links to Sealed Depositions User: Password: DATE NAME LINK 4/22/2016 Ghislaine Maxwell https://spaces.hightail.com/receive/N0tSAdFhh7 5/18/2016 https://spaces.hightail.com/receive/svUd9Wv5LS 6/1/2016 blaijhpaces.hightail.com/receiveNOPXca2Ze)( 6/3/2016 https://spaces.hightail.com/receive/K7YK2HUHFP 6/10/2020 https://spaces.hightail.com/receive/YelAXWYDOd 6/21/2016 hitufhpares.hightail.com/rereivoijhSKPirlis7 7/22/2016 Ghislaine Maxwell https/Spaces.hightail.com/receive/bGq7xlruhf 9/8/2016 Brittany Henderson iht ps://s
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COHEN & GRESSER LLP
GG COHEN & GRESSER LLP Christian R. Evercle11 +1 (212) 957-7600 ccvcrdclIgathcngresscr.com October 13, 2020 BY EMAIL. , Esq. Esq. Esq. United States Attorney's Office Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear 000 Thud Avenue New Yoek. NY 10022 +1 212 957 7600 phone owswoohensresser corn We write on behalf of our client, Ghislaine Maxwell, to set forth requests for discovery and Brady material. Based on our review of the government's productions of August 5, 2019, August 13, 2019, and August 21, 2020, we make the following requests for discovery, inspection, and copying, in accordance with the guarantees of the Fourth, Fifth, and Sixth Amendments, Rule 16 of the Federal Rules of Criminal Procedure, the Federal Rules of Evidence, and such other laws and rules as may be applicable. We are still reviewing these productions, as well as the government's most recent production of
LAW FIRM
MARSH LAW FIRM JENNIFER FREEMAN, ESQ New York, New York 10001 May 2, 2023 The Honorable Christopher Wray Director Federal Bureau of Investigation Michael E. Horowitz Inspector General U.S. Department of Justice Washington, D.C. 20535 Washington, D.C. 20530 The Honorable Merrick B. Garland Attorney General U.S. De artment of ustice NW Washington, D.C. 20530 Via Email and US. Mail Dear Director Wray, Inspector General Horowitz, and Attorney General Garland: As counsel to many survivors of the Jeffrey Epstein sex trafficking conspiracy, we write regarding the failure of the Federal Bureau of Investigation (FBI) to properly, adequately, or timely investigate the sex trafficking of hundreds of girls and young women. The FBI utterly failed to investigate serious allegations involving Epstein's, and perhaps others, child sex abuse materials (CSAM), significant additional criminality which, until recently, has been disregarded, disrespected, and essentially denied.
Ca_4ate.24h24/43134.01FrietibtOrtlefifitin0a0le28013,8111$2eafiabef146f 22
Ca_4ate.24h24/43134.01FrietibtOrtlefifitin0a0le28013,8111$2eafiabef146f 22 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Reply In Support Of Iler Objections to tnsealinu Sealed Materials Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue EFTA00074964 Ca_QatIgt24743tictoWneDbtOrfiefiVIMOXIle?BOWERKVaffizte12401 22 Introduction This Court asked the parties to brief three issues: "(a) the weight of presumption of public access that should be afforded to an item, (b) the identification and weight of any countervailing interests supporting continued sealing/redaction of the item, and (c) whether the countervailing interests rebut the presumption of public access to the item." DE 1044 at 1. Plaintiff and the Miami Herald's responses improperly afford the highest level of presumption to discovery dispute documents, deny that any co
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,
Haddon. Morgan and Foreman, e c
Haddon. Morgan and Foreman, e c Laura A. Menninger II A I> DO N MORGAN FOREMAN April 6. 2016 Via Email ISO East 10th Avenue Denver. Colorado 80203 Re: Giuffre Maxwell, 15-cv-07433-RWS I appreciate your taking the time to talk to me yesterday. As you know, I represent Ghislaine Maxwell in the United States District Court for the Southern District of New York in a defamation action brought by Plaintiff :aka Jane Doe #3). During the course of discovery disputes Ms. Sigrid McCawley, counsel for represented to the Hon. Robert W. Sweet that my client is "under investigation" by an unidentified law enforcement agency. She argues, therefore, that she can withhold documents based initially on a supposed "investigative privilege" and then later on a "public interest privilege." I am unaware as to how either of these supposed "privileges" would apply to 10•1114,1imi Regardless, because you are the only person employed by the government who I am aware has knowledge of some of
Ghislaine Maxwell Deposition Transcript
EXHIBIT 6 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - - - - - - x VIRGINIA L. GIUFFRE, Plaintiff, Case No.: 15-cv-07433-RWS -againstGHISLAINE MAXWELL, Defendants. - - - - - - - - - - - - - - - - - - - - x **CONFIDENTIAL** Videotaped deposition of GHISLAINE MAXWELL, taken pursuant to subpoena, was held at the law offices of BOIES SCHILLER & FLEXNER, 575 Lexington Avenue, New York, New York, commencing April 22, 2016, 9:04 a.m., on the above
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