To: Jeff Pagliuca
Summary
From: " To: Jeff Pagliuca Cc: Sabina Mariella "Si McCawley Laura Mennin er Subject: RE: Documents Per Judge Nathan's Order Date: Thu, 22 Apr 2021 01:20:49 +0000 Attachments: Ex._B_2021.04.05_BSF_Reply_re_Maxwell_Rule_17(c)_Subpoena_- _Prpsd_Redact.._[Govemment_Proposed_Redactions].pdf; 2021.04.05 JEISF_Reply_re_Maxwell_Rule_17(c)_Subpoent[Govemment_Proposed_Reda ctions].pdf; 2021.04.19_LAM_Joint_Letter_with_BSF_re_redactiontin_Rule_17_pleadingsiGovemm ent_Proposed_Redactions].pdf; 2021.04.02_Defts_Resp_to_BSF_Ltr._Motn_to_Quash_Rule_17_SubiGovernment_Propos ed Redactions].pdf; Ex. A_2021.04.02_Defts_Resp_to_BSF_Ltr._Motn_to_Quash_Rule_17_Sub_- Prp;c1.._[Govemment_Proposed_Redactions].pdf Good evening, Our team has reviewed the documents and intends to propose a limited number of redactions to protect third party privacy interests. Attached please find pdfs with our proposed redactions in red boxes. Would you please let me know your respective positions regarding th
Persons Referenced (5)
“...l 21, 2021 7:00 PM To: Jeff Pagliuca Cc: Sabina Mariella S; Sigrid McCawley Laura Menninger < >; Nicole Simmons (t > Subject: RE: Documents Per Judge Nathan's Order Rece...”
Sigrid McCawley“...: Wednesday, April 21, 2021 7:00 PM To: Jeff Pagliuca Cc: Sabina Mariella S; Sigrid McCawley Laura Menninger < >; Nicole Simmons (t > Subject: RE: Documents Per Judge Nat...”
Nicole Simmons“...o: Jeff Pagliuca Cc: Sabina Mariella S; Sigrid McCawley Laura Menninger < >; Nicole Simmons (t > Subject: RE: Documents Per Judge Nathan's Order Received, thank you very...”
United States“...ill file a letter with the Court setting forth our proposal. Best, Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York, NY 100...”
United States Attorney“...ill file a letter with the Court setting forth our proposal. Best, Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 From:...”
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EFTA DisclosureRelated Documents (6)
Case 20-2413, Document 44, 08/20/2020, 2913556, Pagel of 78
Case 20-2413, Document 44, 08/20/2020, 2913556, Pagel of 78 20-2413 United States Court of Appeals for the Second Circuit —against— GHISLAINE MAXWELL, SHARON CHURCHER, JEFFREY EPSTEIN, PlaintiffiAppellee, Defendant-Appellant, 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) APPENDIX Volume IV of VIII (Pages App.-0777 to App.-0852) Ty Gee Adam Mueller HADDON, MORGAN AND FOREMAN, P.C. Attorneys or e en ant-Appellant Ghislaine Maxwell EFTA00076383 Case 20-2413, Document 44, 08/20/2020, 2913556, Paget of 78 Docket Entries App.-0001 Order regarding Ms. Maxwell's Letter Motion to Reconsider July 23, 2020 Ruling, Dated July 29, 2020 (Dkt. 1079) App.-0777 Notice of Appeal, Dated July 29, 2020 (Dkt. 1081) App.-0781 Non-Redacted Declaration of Sigrid S. McCawley In Support of Plaintiff's
COHEN & GRESSER LLP
COHEN & GRESSER LLP .,:m.cohengesser <cm October 13, 2020 BY EMAIL United States Attorney's Office w York Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear 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 October 2, 2020, and reserve the right to supplement these requests as necessary. 1. We request any oral, written, or recorded statements made by Ms. Maxwell, aside from the statements made in prior civil case proceed
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,
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
mid Avenue
mid Avenue COHEN & GRESSER LLP October 13, 2020 BY EMAIL , Esq. Esq. Esq. United States Attorney's Office Southern District of New York New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear 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 October 2, 2020, and reserve the right to supplement these requests as necessary. 1. We request any oral, written, or recorded statements made by Ms. Maxwell, aside
Virginia Roberts v. Alan Dershowitz – Allegations of Sex Trafficking, NPA Manipulation, and Defamation
The complaint provides a dense web of alleged connections between Alan Dershowitz, Jeffrey Epstein, former U.S. Attorney Alexander Acosta, and the 2008 non‑prosecution agreement (NPA). It cites specif Roberts alleges she was trafficked by Epstein from 2000‑2002 and forced to have sex with Dershowitz. Dershowitz is accused of helping draft and pressure the government into the 2008 NPA that shielded
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