(USAFLS)" <1
Summary
From: (USAFLS)" <1 To: ' (USAFLS)" Subject: Re: Ghislaine Maxwell Date: Wed, 13 Apr 2016 14:55:49 +0000 Importance: Normal Inline-Images: image001.jpg (USAFLS)" If my edits make sense to both of you, I guess there's no reason we need to talk about them. On Apr 12, 2016, at 7:20 PM, (USAFLS) < > wrote: Here is my suggestion regarding a response, but we should discuss tomorrow. -Ed Dear Ms. Menninger: I am in receipt of your letter of April 6, 2016, where you have attempted to memorialize a telephone conversation in which you called me concerning Giuffre' Maxwell, Case No. 15-cv-07433-RWS (S.D.N.Y.), a civil case of which I have no knowledge beyond what you have represented. With respect to your understanding of our telephone conversation, let me make some clarifications. Due to pending litigation that was instituted against the U.S. Attorney's Office for the Southern District of Florida (the "Office"), the Office was recused by the Department of Justice from prospe
Persons Referenced (5)
“...name. I am running off to the OLEOs, but maybe we can discuss tomorrow? From: Laura Menninger Sent: WednescSSA06, 2016 4:11 PM To: , 1. (USAFLS) Subject: Ghislaine Maxwell Ms. Please see att...”
United States“...2016, where you have attempted to memorialize our telephone conversation. The United States and the U.S. Attorney's Office are not parties to your suit and I am unaware of...”
U.S. Attorney“...some clarifications. Due to pending litigation that was instituted against the U.S. Attorney's Office for the Southern District of Florida (the "Office"), the Office was recused by the Department of...”
Ghislaine Maxwell“...From: (USAFLS)" <1 To: ' (USAFLS)" Subject: Re: Ghislaine Maxwell Date: Wed, 13 Apr 2016 14:55:49 +0000 Importance: Normal Inline-Images: image001.jpg (USAFLS)" If my edits make sense to bo...”
Jeffrey Epstein“...onsibility for any criminal investigation or potential prosecution relating to Jeffrey Epstein's alleged sexual activities with minor females. As a result, the Office was also recused from any crimi...”
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EFTA DisclosureRelated Documents (6)
U.S. Department of Justice
U.S. Department of Justice United States Attorney Southern District of New York The Silvio I. Motto Building One Saint Andrew's Plaza New York. New York 10007 October 20, 2020 BY ELECTRONIC MAIL Christian Everdell, Esq. Mark Cohen, Esq. Cohen & Gresser LLP 800 Third Avenue New York, NY 10022 Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C. 150 East Tenth Avenue Denver, CO 80203 Bobbi Sternheim, Esq. Law Offices of Bobbi C. Sternheim 33 West 19th Street-4th Fl. New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Counsel: In recognition of the Government's ongoing discovery obligations, today we are producing copies of the materials listed in the below index, which materials are stamped with control numbers SDNY_GM_00328070 through SDNY_GM_00356148. The password for the drive is "USAOsdnyl!". The materials are available for pickup at the U.S. Attorney's Office in Manhattan. Please note that both this l
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
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
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
Subject: FW: Ghislaine Maxwell
Subject: FW: Ghislaine Maxwell Date: Thu, 07 Apr 2016 16:33:38 +0000 Importance: Normal Attachments: 2016.04.05_Ltr to_ df Inline-Images: image001.jpg This attorney for Ghislaine Maxwell called me and I picked up the call without knowing who it was. She asked me a series of questions which she claims that she wants to use in the civil suit between Ms. Maxwell and' ;. I have attached her "confirming letter," which doesn't exactly capture what I said to her. I have no desire to be part of that suit and know nothing about it, but I also don't want her misrepresenting what I said. Any thoughts or advice? I thought about something like: Dear Ms. Menninger: I am in receipt of your letter of April 6, 2016, where you have attempted to memorialize our telephone conversation. The United States and the U.S. Attorney's Office are not parties to your suit and I am unaware of the representations that you discuss beyond what you have told me. To clarify, due to pending litigation, th
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.
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