Haddon, Morgan and Foreman, P.C
OrganizationRelationship Network
EFTA00014982.pdf
Legal correspondence from Ghislaine Maxwell's defense attorney, Jeffrey Pagliuca, to the US Attorney's Office regarding objections to hearsay statements. The defense objects to statements made by Epstein to employees (specifically CC-1) about Maxwell 'finding girls' and instructions regarding computer removal, arguing these occurred post-conspiracy and constitute 'idle chatter' rather than furtherance of a conspiracy. The letter also addresses the scope of 'minor victims' referenced in the indictment versus those in Florida investigations.
DOJ-OGR-00008431.jpg
This legal document is a letter dated December 15, 2021, from defense attorney Jeffrey S. Pagliuca to Judge Alison J. Nathan regarding the case of United States v. Ghislaine Maxwell. The letter is a response to the government's motion to prevent a witness, Alexander Hamilton, from testifying about four specific topics related to an individual named 'Kate'. The defense argues that providing Hamilton's declaration to the government under Rule 26.2 does not obligate them to introduce all of its contents as evidence.
DOJ-OGR-00008425.jpg
This is a legal letter dated December 16, 2021, from attorney Jeffrey S. Pagliuca to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter presents legal arguments concerning the impeachment of witnesses using inconsistent statements and '3500 material' (Jencks Act disclosures), citing specific case law to support the defense's procedural approach.
DOJ-OGR-00008364.jpg
A letter dated December 13, 2021, from defense attorney Jeffrey S. Pagliuca to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter informs the court of the defense's intention to question attorneys Jack Scarola, Brad Edwards, and Robert Glassman and argues that these questions do not violate attorney-client privilege. The document cites legal precedents regarding the burden of proof for privilege claims.
DOJ-OGR-00008225.jpg
This document is a legal letter dated December 5, 2021, from defense attorney Jeffrey S. Pagliuca to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The defense objects to the government's attempt to introduce the '900 series' of photographs of Jeffrey Epstein's New York apartment taken in 2019, arguing they have not been authenticated as accurately representing the apartment during the relevant timeframe of 1994-1996. The letter urges the court to reaffirm its previous ruling from December 3 excluding the photos based on Rules 401 and 403.
DOJ-OGR-00001752.jpg
This document is a letter motion dated August 17, 2020, from attorney Jeffrey Pagliuca on behalf of his client, defendant Ghislaine Maxwell, to Judge Alison J. Nathan of the U.S. District Court for the Southern District of New York. The motion requests a modification of the existing protective order to allow Maxwell's defense to refer to and file under seal certain discovery materials provided by the government on August 5 and August 13, 2020. The defense argues this is necessary for the fair determination of issues in what is referred to as the "Other Matters".
DOJ-OGR-00001635.jpg
This is a legal letter dated July 21, 2020, from Jeffrey Pagliuca of Haddon, Morgan and Foreman, P.C., to Judge Alison J. Nathan of the Southern District of New York. The attorney, representing defendant Ghislaine Maxwell, requests that the court issue an order prohibiting the U.S. Government and its affiliates from making extrajudicial statements about the case, arguing such statements are prejudicial and violate Maxwell's Sixth Amendment right to a fair trial.
DOJ-OGR-00019574.jpg
This document is a legal reply from Ghislaine Maxwell's attorney, Jeffrey Pagliuca, to Judge Alison J. Nathan, dated August 24, 2020. It supports a request to modify a protective order to allow Maxwell to disclose to an adversary in a separate civil litigation that said adversary has already provided materials to the U.S. Attorney's Office via subpoena. The document argues against the government's stance that the civil litigation is unrelated and that disclosure would jeopardize the criminal investigation.
DOJ-OGR-00019490.jpg
This document is a letter dated July 21, 2020, from attorney Jeffrey Pagliuca to Judge Alison J. Nathan of the Southern District of New York. On behalf of his client, Ghislaine Maxwell, Pagliuca requests a court order to prohibit the government and its agents from making extrajudicial statements about her case. The letter argues that such statements are prejudicial and violate Maxwell's Sixth Amendment right to a fair trial by an impartial jury, citing legal precedents to support the court's authority to issue such an order.
DOJ-OGR-00009617.jpg
This legal document is a letter dated March 2, 2022, from attorney Jeffrey S. Pagliuca to Judge Alison J. Nathan. Pagliuca, on behalf of his client Ghislaine Maxwell, requests an adjournment of a hearing on a Motion for New Trial, originally scheduled for March 8. The reason for the request is the unavailability of Maxwell's legal counsel, including Pagliuca, Ms. Menninger, and Ms. Sternheim, due to their mandatory participation in other lengthy trials in Colorado and New York.
DOJ-OGR-00002888.jpg
This document is a legal letter filed on April 5, 2021, by Laura A. Menninger, counsel for Ghislaine Maxwell, to Judge Alison J. Nathan. The letter requests a one-week continuance for the arraignment on the S2 Indictment, moving it from April 16 to April 23, 2021, due to a scheduling conflict in Colorado and ongoing evidence review. The letter notes that the government does not oppose the request and mentions that the delay would allow Maxwell's family time to arrange travel to attend.
DOJ-OGR-00008804.jpg
This document is a letter dated January 5, 2022, from attorney Jeffrey S. Pagliuca to Judge Alison J. Nathan regarding the case of United States v. Ghislaine Maxwell. Pagliuca argues against the government's request for a hearing concerning a juror who revealed post-trial that they were a victim of sexual assault. He contends the request is premature and that, based on publicly available information and legal precedent, the court should order a new trial without an evidentiary hearing.
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein entity