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Summary
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 Inline-Images: image00 ljpg; image002.jpg Jeff, You're absolutely correct and I'm sorry for the delay. Attached please find the form proffer letter, as discussed. And it is on our calendar to have a call on this Thursday the 11th, 4 p.m. your time (and 6 p.m. our time). 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 Simmon Subject: RE: Maxwell Hello, I expect you all have been busy in the last few days. When we spoke yesterday I understood that you would be sending a form proffer letter for my review. I would like to discuss the document with my client as soon as possible to keep the process moving. When you get a chance please send the draft
Persons Referenced (4)
“...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...”
Nicole SimmonsUnited States“...hanks very much, and looking forward to discussing further tomorrow. Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY...”
United States Attorney“...hanks very much, and looking forward to discussing further tomorrow. Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007 F...”
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EFTA DisclosureRelated Documents (6)
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From:' "G To:' " Subject: FW: Maxwell Date: Mon, 15 Jul 2019 19:46:42 +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. When we spoke yesterday I understood that you would be sending a form proffer letter for my review. I would like to discuss the document with my client as soon as possible to keep the process moving. When you get a chance please send the draft and I will hopefully be 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, and any documents, files or previou
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From: " )" < To: 'Jeff Pagliticze -cjpagliucaghmflaw.com> Cc: Nicole Simmons <nsimmons Subject: RE: Maxwell Date: Sun, 07 Jul 2019 19:45:37 +0000 thmflaw.com>, ' )'' Importance: Normal Attachments: 2019-07-07, JE,_individual_subpoena,_Ghislaine Maxwell.pdf Inline-Images: image001.jpg Jeff, Thanks for speaking with me this afternoon. I've copied my colleagues, and S so that you have everyone's contact information. In terms of scheduling a call tomorrow, we are going to be tied up in the morning, and the afternoon is a bit uncertain given that we are not sure yet of the timing of the presentment for Mr. Epstein. I think it would make sense to plan for a call at 4, and we can let you know if we need to reschedule, if that's alright with you. Attached is the subpoena for Ms. Maxwell. The indictment is currently under seal, but we anticipate that it will be unsealed tomorrow morning and publicly available. Please let us know tomorrow if you have any difficulty and we can
Cagean.g0c44/ 71SEAFierbd664164i igl5V2PilaW6M/Joagria44
Cagean.g0c44/ 71SEAFierbd664164i igl5V2PilaW6M/Joagria44 1?)f 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-LAP Ms. Maxwell's Objections to Unsealing Docket Entries 143. 173. and 199 and to Unsealing Docket Entries 164 and 230 at This Time. Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 EFTA00075004 CageaUlg0caAIDer0dthhilfii igl5V2Pil&iA6/2bagctacir4 2%f 3 Defendant Ghislaine Maxwell, through her counsel and pursuant to this Court's Order and Protocol for Unsealing Decided Motions, DE 1044, as clarified by DE 1053, objects to the unsealing of the Sealed Items contained in: • DE 143 (and related DEs 142, 144, 144-1, 149, 150, 150-1, 151, 152, 153, and 153- 1); • DE 172 (and related DEs 171, 173, 173-1, 189, 190, 190-1, 202, 203, 204-1, 211, 212, 212-1, and 224) and; • DE 199 (and related DEs 200, 200-1, 228,2 29,
From: '
From: ' )11 To: a )11 Subject: RE: Maxwell Date: Sun, 07 Jul 2019 20:10:22 +0000 Importance: Normal Inline-Images: image001.jpg Yes, you're right, 4 his time and 6 ours. Here's hoping the presentment is done by then... From: Sent: Sunday, July 7, 2019 4:03 PM To: Subject: FW: Maxwell If I'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 information. < and S so that you In terms of scheduling a call tomorrow, we are going to be tied up in the morning, and the afternoon is a bit uncertain given that we are not sure yet of the timing of the presentment for Mr. Epstein. I think it would make sense to plan for a call at 4, and we can let you know if we need to reschedule, if that's alright with you. Attached is
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x S2 20 Cr. 330 (AJN) MS. MAXWELL'S MOTION FOR AN ORDER AUTHORIZING A SUBPOENA PURSUANT TO FED. R. CRIM. P 17(c)(3) Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver CO 80203 Phone: Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York NY 10022 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 225 Broadway, Suite 715 New York NY 10007 Phone: Attorneys for Chislaine Maxwell EFTA00105542 Defendant Ghislaine Maxwell requests that the Court enter an Order authorizing her counsel to issue a subpoena under Federal Rule of Criminal Procedure 17(c) to Epstein Victim's Compensation Program, for certain items identified in Attachment A to the proposed Subpoena, together attached as Exhibit 1 to this Motion, for the following reasons: I. Background On October 11, 2021, the gove
To: Jeff Pagliuc
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 from you that our call was canceled. Why don't you all let us know when you want to reschedule for, and with whom, and we'll go from there. thanks, From: Jeff Pagliuc. Sent: Monday, July 15, 2019 16:15 To: Cc: Nicole Subject: Re: Maxwell < Sorry I missed your call. I had to travel to North Carolina over the weekend to assist with some family issues. I am on my way back to Denver now. I have a court appearance in Aspen, Colorado tomorrow and should have quite a bit of phone availability during the drive. I assume Mark updated you on our status and am happy to discuss further when I am available. Jeff On Jul 9, 2019, at 7:36 PM, Jeff, wrote: You're absolutely correct and I'm sorry for the delay. Attached please find the form proffer letter, as discussed. And it is on our calendar to have a call on
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