Haddon. Morgan and Foreman, e c
Summary
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
Persons Referenced (5)
“... 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 uni...”
United StatesGhislaine MaxwellJeffrey Epstein“... Ms. Maxwell was not named in any non-prosecution agreement with or concerning Jeffrey Epstein. EFTA00211500 Page 2 If I have misunderstood any of those statements, please let me know. Thank you ...”
ROBERT W. SWEET“...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, therefor...”
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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
Court Transcript Reveals Potential Undisclosed Evidence and High‑Profile Connections in Giuffre v. Maxwell Defamation Case
The transcript contains several concrete references that could be pursued for investigative value: attempts to depose former President Bill Clinton; FOIA requests and alleged FBI involvement (Louie Fr Plaintiff’s counsel sought to depose Bill Clinton to establish his relationship with Epstein. Reference to former FBI Director Louis Freeh as an expert witness without a Rule 26 disclosure. Discussio
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X IN RE APPLICATION TO UNSEAL CIVIL : SEALED AFFIRMATION AND DISCOVERY MATERIALS, APPLICATION USAO Reference No. 2018R01618. X pursuant to Title 28, United States Code, Section 1746, hereby declares under penalty of perjury: 1. I am an Assistant United States Attorney in the office of Geoffrey S. Berman, United States Attorney for the Southern District of New York. I make this Affirmation and Application, pursuant to the All Writs Act, Title 28, United States Code, Section 1651, for a limited order to unseal discovery materials in the possession of Boies Schiller & Flexner LLP, in connection with the matter of v. Ghislaine Maxwell, et al.. 15 Civ. 7433 (RWS) (S.D.N.Y.). As further discussed below, the materials are currently subject to a protective order issued by this Court. The Government seeks these materials in connection with a federal grand jury investigation. 2. On or about September 21, 2015, p
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.
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
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
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