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037.pdf
This court document from April 7, 2017, details a 'Notice of Submission of Witness Solicitation Materials' filed in the case of Bradley J. Edwards v. Ghislaine Maxwell. Plaintiff Virginia Giuffre submitted witness solicitation materials for in camera review as per a March 23, 2017, court ruling. The document also includes a certificate of service, confirming electronic filing and service to attorneys Laura A. Menninger and Jeffrey S. Pagliuca.
005.pdf
This document is a Motion to Appear Pro Hac Vice filed on June 29, 2016, in the Southern District of Florida. Attorney Denise D. Riley requests that attorney Jeffrey S. Pagliuca of the Colorado firm Haddon, Morgan and Foreman be admitted to represent Defendant Ghislaine Maxwell in matters related to a subpoena issued to Bradley J. Edwards. The document includes contact information for the attorneys involved and a certificate of service to opposing counsel Jack Scarola.
EFTA00030900.pdf
An email dated August 9, 2020, from attorney Jeff Pagliuca to redacted recipients and several cc'd attorneys (Menninger, Everdell, Cohen, Simmons). The email transmits an attached conferral letter regarding a protective order and discovery to the USA (likely US Attorney). The document originates from the Ghislaine Maxwell defense team (Haddon, Morgan and Foreman; Cohen Gresser).
EFTA00027169.pdf
Defense attorney Jeffrey Pagliuca writes to Judge Alison Nathan arguing against the government's request to defer ruling on Ghislaine Maxwell's motion to suppress evidence until after the trial on non-perjury counts. The defense contends that an evidentiary hearing is necessary immediately because the government's alleged misconduct (misleading a judge to obtain a subpoena) constitutes a due process violation that could suppress all 90,000 pages of evidence and any derivatives ('fruit of the poisonous tree'). Furthermore, the defense argues that Maxwell cannot knowingly decide whether to testify without knowing the admissibility of this evidence, as the government has only promised not to use it in its case-in-chief but reserved rights for impeachment.
EFTA00016720.pdf
This document is a letter from defense attorney Jeffrey Pagliuca to Judge Alison Nathan dated October 14, 2021, regarding the case United States v. Ghislaine Maxwell. The defense requests confirmation that the deadline for filing a motion under Federal Rule of Evidence 412 (regarding alleged victims' sexual behavior) is November 15, 2021. The letter argues that recent massive discovery disclosures (over 8,000 pages of 3500 material) and notices regarding Rule 404(b) witnesses received just three days prior require additional time for review, especially given Maxwell's incarceration.
EFTA00014710.pdf
This document is an email chain from November 2021 regarding *U.S. v. Maxwell*. Defense attorneys Bobbi Sternheim and Nicole Simmons communicate with Judge Nathan's chambers about submitting Ghislaine Maxwell's response to motions to quash a subpoena issued to the Epstein Victims' Compensation Program (EVCP). The correspondence confirms that the response was submitted under temporary seal and that the government and moving parties were subsequently served after redactions were handled.
EFTA00014699.pdf
This document is an email chain from November 22, 2021, regarding the legal case U.S. v. Maxwell. Defense attorneys (Sternheim and Simmons) communicate with Judge Nathan's chambers regarding the submission of Maxwell's response to motions to quash a subpoena issued to the Epstein Victims' Compensation Program (EVCP). The correspondence confirms that the EVCP has been served and discusses protocols for redactions and serving the moving parties.
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-00001741.jpg
This document is a letter motion dated August 24, 2020, from attorney Laura A. Menninger to Judge Alison J. Nathan of the Southern District of New York. The attorney requests permission to file documents under seal on behalf of her client, Ghislaine Maxwell, in the case of United States v. Ghislaine Maxwell. The justification for the request is that the documents contain information designated as confidential by the Government under the terms of the existing Protective Order in the case.
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-00001581.jpg
This document is the cover page for a legal filing, specifically a memorandum submitted on behalf of defendant Ghislaine Maxwell. Filed on July 10, 2020, in the U.S. District Court for the Southern District of New York, the document outlines Maxwell's opposition to the government's motion for her detention. The filing lists her legal counsel from the law firms COHEN & GRESSER LLP and HADDON, MORGAN & FORMAN P.C.
DOJ-OGR-00001241.jpg
This document is the conclusion of a legal filing, dated February 23, 2021, submitted by the legal team of Ghislaine Maxwell. The attorneys argue that proposed restrictive bail conditions, including renunciation of foreign citizenship and asset monitoring, are sufficient to ensure her appearance at trial. They conclude that denying bail under these circumstances would constitute a miscarriage of justice.
DOJ-OGR-00002382.jpg
This document is a Certificate of Service dated March 4, 2016, from a legal case (1:15-cv-00384-RW). Sigrid S. McCawley certifies that she electronically filed a document with the Clerk of Court and served it on Laura A. Menninger of the law firm Haddon, Morgan & Foreman, P.C. via the court's electronic filing system (CM/ECF).
DOJ-OGR-00002321.jpg
This document is the cover page for a legal memorandum filed on January 25, 2021, in the Southern District of New York (Case 20 Cr. 330). It is a filing by Ghislaine Maxwell's defense team supporting a motion to dismiss a superseding indictment based on alleged Sixth Amendment violations. The page lists the defense attorneys from three different law firms representing Maxwell.
DOJ-OGR-00002321(1).jpg
This document is the cover page for a legal memorandum filed on January 25, 2021, in the United States District Court for the Southern District of New York. The filing is made by the attorneys for defendant Ghislaine Maxwell in the case of United States v. Ghislaine Maxwell. The memorandum supports a motion to dismiss the superseding indictment against Maxwell, arguing it was obtained in violation of the Sixth Amendment.
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-00019563.jpg
This document is a letter motion filed on September 2, 2020 (dated August 17), from Ghislaine Maxwell's attorney, Jeffrey Pagliuca, to Judge Alison J. Nathan. Maxwell requests permission to use specific discovery materials produced by the government in early August 2020 in redacted 'Other Matters' (likely separate legal proceedings). The document contains significant redactions concealing the specific nature of these other matters and the content of the discovery materials.
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-00019340.jpg
This legal document is a letter dated September 15, 2020, from attorney Adam Mueller of Haddon, Morgan and Foreman, P.C., to Gerard Whidbee at the U.S. Court of Appeals for the Second Circuit. Mueller, representing Defendant-Appellant Ghislaine Maxwell, formally selects October 22, 2020, as the due date for filing her opening brief in the case of United States v. Maxwell.
DOJ-OGR-00019321.jpg
This is a letter dated August 10, 2020, from Ghislaine Maxwell's attorney, Laura A. Menninger, to Judge Loretta A. Preska. The letter informs the court about newly discovered information that is critical to both Maxwell's civil case (Giuffre v. Maxwell) and her separate criminal case. Counsel explains they are currently barred from disclosing this information due to a protective order in the criminal case but intend to seek a modification of that order to share the details with the court.
DOJ-OGR-00019243.jpg
This document is a letter dated September 3, 2020, from Nicole Simmons of the law firm Haddon, Morgan and Foreman, P.C. to the Clerk of Court for the Southern District of New York. The letter serves as a cover for a 'Notice of Appeal' being filed in the case of 'US v. Maxwell' (Case No. 20 cr. 330). It also confirms the enclosure of a check for $505.00 to cover docketing and processing fees.
DOJ-OGR-00008925.jpg
This document is the cover page for a legal filing in the case of United States of America v. Ghislaine Maxwell, filed on February 11, 2022, in the U.S. District Court for the Southern District of New York. It is an omnibus memorandum submitted by Maxwell's legal team in support of her post-trial motions. The document lists the names and contact information for her attorneys from three different law firms.
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