k7e2MaxC kjc
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k7e2MaxC kjc 1 UNITED STATES DISTRICT COURT 2 SOUTHERN DISTRICT OF NEW YORK 3 UNITED STATES OF AMERICA, New York, N.Y. 4 v. 20 Cr. 330 (AJN) 5 GHISLAINE MAXWELL, 6 Defendant. 7 X Teleconference 8 Arraignment 9 Bail Hearing 10 July 14, 2020 3:05 p.m. 11 Before: 12 13 HON. ALISON J. NATHAN, 14 District Judge 15 APPEARANCES 16 AUDREY STRAUSS 17 United States Attorney for the Southern District of New York BY: 18 19 Assistant United States Attorneys 20 21 COHEN & GRESSER, LLP Attorneys for Defendant 22 BY: MARK S. COHEN CHRISTIAN R. EVERDELL 23 24 HADDON MORGAN & FOREMAN, P.C. Attorneys for Defendant 25 BY: JEFFREY S. PAGLIUCA LAURA A. MENNINGER SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 3514.014 Page I of 3 SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17 EFTA_00007714 EFTA00158775 2 3 4 5 k7e2MaxC kjc she believes she risks prison, she will never come back. If she is out, I need to be protected. I
Persons Referenced (8)
“...ds of Jane Doe. 7 THE COURT: All right. Thank you. 8 would you indicate how the victim who wishes 9 to be heard should be recognized? 10 Yes, your Honor. 11 The...”
United StatesUnited States AttorneyGhislaine Maxwell“...YORK 3 UNITED STATES OF AMERICA, New York, N.Y. 4 v. 20 Cr. 330 (AJN) 5 GHISLAINE MAXWELL, 6 Defendant. 7 X Teleconference 8 Arraignment 9 Bail Hearing 10 July 14, 2020 3:05 p.m....”
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Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 1 of 161
Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 1 of 161 EXHIBIT E EFTA00084366 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 2 of 161 New Jeffrey Epstein accuser says he molested her at 13, told her to wear children's underwear January 18.2020 I 12-04am I Updated Jeffrey Epstein A woman claiming she was Jeffrey Epstein's "first-known victim" says she was sexually abused by the now-dead pedophile — who called himself her "Godfather" — when she was 13 years old. Jane Doe met Epstein and his friend, Ghislaine Maxwell. in the summer of 1994 at Michigan's Interlochen Arts Camp, where she was In voice training, according to newly filed court papers suing Epstein's estate and Maxwell. The duo quickly took her under their wing, taking her to movies and on shopping trips in her home state of Florida and all the while grooming her for abuse, the Manhattan federal court suit says. Epstein "started to slowly display his pedophilic ways when shopping with Doe
k7e2MaxC kjc
k7e2MaxC kjc UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. Before: New York, N.Y. 20 Cr. 330 (AJN) x Teleconference Arraignment Bail Hearing July 14, 2020 3:05 p.m. HON. ALISON J. NATHAN, District Judge APPEARANCES AUDREY STRAUSS United States Attorney for the Southern District of New York BY: Assistant United States Attorneys COHEN & GRESSER, LLP Attorneys for Defendant BY: MARK S. COHEN CHRISTIAN R. EVERDELL HADDON MORGAN & FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA LAURA A. MENNINGER SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00066216 k7e2MaxC kjc THE COURT: Good afternoon, everyone. This is Judge Nathan presiding. This is United States v. Ghislaine Maxwell, 20 Cr. 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 330. I will tak
Ces2e.29-12,407413r3cliAlienDtidutinEl t310282 if663615/233/2174ig Plage aoat 9
Ces2e.29-12,407413r3cliAlienDtidutinEl t310282 if663615/233/2174ig Plage aoat 9 HADDON MORGAN FOREMAN July 29, 2020 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Haddon, Morgan and Foreman, P C Ty Gee 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 HI 303.832.2628 www.hmllaw.com [email protected] Re: Reconsideration of the Court's July 23 Ruling Giuffie v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: As counsel for Ms. Maxwell we write to request that the Court vindicate its Protective Order and punish its violation. Ms. Maxwell's two deposition transcripts were designated "Confidential" and subject to the protection of the Protective Order. Both transcripts ended up in the hands of the government, which used them to bring an indictment against Ms. Maxwell, charging her with, among other things, perjury in her deposition testimony. This is a serious violation
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. : 20 Cr. 330 (MN) x 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 BOIES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denverile. Phone: Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York NY 10011 Phone: Attorneys for Ghislaine Maxwell EFTA00086658 TABLE OF CONTENTS TABLE OF CONTENTS TABLE OF AUTHORITIES ii TABLE OF EXHIBITS iv INTRODUCTION AND SUMMARY OF THE ARGUMENT 1 FACTUAL BACKGROUND 2 A. The Protective Order Maxwell 2 B. Maxwell's April and July 2016 depositions 4 C. The Settlement A
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
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x S2 20 Cr. 330 (AJN) UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. x 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. Christian R. Everdell COHEN & GRESSER LLP Bobbi C. Stemheim Law Offices of Bobbi . Stemheim Attorneys for Chislaine Maxwell EFTA00040126 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 Administrator, 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 government began producing 3500 material to the defense. These rolling productions confirmed that the four Accusers referenced in the
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