Denver, Colorado
LocationRelationship Network
001-01.pdf
Legal declaration by attorney Bradley J. Edwards filed on June 13, 2016, in support of a motion to quash a subpoena from Ghislaine Maxwell. Edwards details his representation of Virginia Giuffre and the undue burden of reviewing over 200,000 emails for communications with journalists. He explicitly states that Ghislaine Maxwell and Jeffrey Epstein share a joint defense agreement and mentions Giuffre's association with the organization 'Victims Refuse Silence, Inc.'
EFTA00032234.pdf
This document is an email dated August 18, 2020, from Nicole Simmons of Haddon, Morgan and Foreman, P.C. to Judge Nathan's chambers. The email serves to transmit a sealed Letter Motion, Affidavit, and ten exhibits on behalf of defendant Ghislaine Maxwell regarding a 'Request to Modify Protective Order' in the case United States v. Ghislaine Maxwell. The filing was made at the request of attorney Jeffrey S. Pagliuca.
EFTA00030068.pdf
An email dated March 8, 2021, from attorney Laura Menninger to the US Attorney's Office (USANYS) and other defense counsel (Pagliuca, Everdell, Sternheim). The email serves as a cover letter for an attached PDF concerning a request to view evidence and highly confidential materials in the case US v. Maxwell (20 Cr. 330).
EFTA00029844.pdf
Defense counsel Laura Menninger objects to government redactions in the case US v. Maxwell. Menninger argues that 'Accuser-2's' diary entries are not confidential as they were shared on a NY Times podcast and do not implicate Maxwell. The letter also argues against redacting information about another accuser (name redacted) who has publicized her allegations via Netflix and podcasts, referencing the 'Kramer notes', and discusses sealing issues related to Maxwell's deposition in a separate civil case ruled on by Judge Preska.
EFTA00028845.pdf
This document is an email chain from March 2021 concerning the US v. Maxwell case, specifically regarding requests from defense counsel to view highly confidential images and physical evidence. The emails detail logistics for reviewing evidence, including questions about image formats, metadata, the need for multiple laptops for review, inventory lists of physical items, and proposed dates and locations for the review at 500 Pearl Street.
EFTA00025147.pdf
This document is an email dated October 28, 2021, from Nicole Simmons of Haddon, Morgan and Foreman, P.C. to Judge Nathan's chambers in the Southern District of New York. It serves as a transmittal for the filing of 'Ms. Maxwell's Reply In Support of Her Motions in Limine' in the case U.S. v. Maxwell (Case No. 20 Cr. 330). The email was sent at the request of attorney Jeffrey Pagliuca.
EFTA00025059.pdf
An email from Nicole Simmons of Haddon, Morgan and Foreman, P.C. to Judge Nathan's chambers, dated October 26, 2021. The email serves as a cover letter for the submission of Ghislaine Maxwell's response to the Government's Omnibus Motions in Limine, sent at the request of attorney Jeffrey Pagliuca.
EFTA00024232.pdf
This document is an email chain from October 2021 regarding the legal case U.S. v. Maxwell. The initial email is from defense attorney Nicole Simmons to Judge Nathan's chambers, submitting Ghislaine Maxwell's reply in support of motions in limine. This email was subsequently forwarded internally within the US Attorney's Office (USANYS) with a note attaching both the defense reply and the government's final brief.
EFTA00021875.pdf
This document is an email chain from August 2020 involving legal counsel for Ghislaine Maxwell (Jeff Pagliuca, Laura Menninger, etc.) and likely government prosecutors (names redacted). The discussion concerns a discovery letter sent by the defense, the handling of criminal grand jury materials in relation to Maxwell's civil cases, and a dispute over the disclosure of victim names. The redacted senders discuss strategy for responding to 'Jeff and Laura,' specifically refuting claims of government malfeasance and debating whether to allow materials to be filed under seal.
EFTA00021697.pdf
This document is an email chain from March 2021 related to the criminal case US v. Maxwell (Ghislaine Maxwell). Defense attorney Laura Menninger emailed prosecutors (USANYS) attaching a letter regarding a request to view 'highly confidential materials' and 'scenes'. This email was then forwarded internally (likely among law enforcement or prosecution team members) with a request to discuss the matter.
EFTA00019849.pdf
An email dated September 23, 2020, from Nicole Simmons of HMF Law (Haddon, Morgan and Foreman) to the US Court of Appeals for the Second Circuit. The email submits an unredacted version of a legal filing regarding the consolidation of cases related to Ghislaine Maxwell (Civil case 20-2413 and Criminal case 20-3061).
EFTA00018515.pdf
This document is a legal memorandum filed by Ghislaine Maxwell's defense team arguing against the government's motion for detention and requesting release on bail. The defense argues that the COVID-19 pandemic poses a severe health risk and impedes defense preparation, and asserts that Maxwell is not a flight risk, citing her presence in the U.S. since Epstein's arrest. They propose a $5 million bond secured by UK property and strict conditions including home confinement and GPS monitoring.
EFTA00016944.pdf
This document is an email chain from October 18-19, 2021, regarding the filing of Motions in Limine in the case U.S. v. Maxwell (Case No. 20 Cr. 330). Defense attorney Nicole Simmons submits the motions to Judge Nathan's chambers on behalf of Jeffrey Pagliuca. Subsequent internal emails among USANYS staff discuss accessing the files, revealing an internal DOJ file path labeled 'USvEpstein-2018R01618'.
EFTA00015968.pdf
This document is an email chain from July 17, 2020, between defense counsel (Christian Everdell and Laura Menninger) and government prosecutors regarding the case of Ghislaine Maxwell (referred to as 'GM' in attachments). The defense provides a proposed Protective Order and argues for specific terms, including the removal of a 'Highly Confidential' designation and the provision of a laptop to Maxwell in the MDC (Metropolitan Detention Center) so she can review discovery materials, as in-person legal visits were not allowed at the time. The email emphasizes the defense's desire to avoid trying the case in the press and cites concerns about witness harassment.
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.
EFTA00014671.pdf
This document is a letter from Ghislaine Maxwell's defense counsel to Judge Alison Nathan, dated May 12, 2021, arguing for the enforcement of a subpoena for evidence controlled by the law firm Boies, Schiller, and Flexner (BSF). The defense seeks the full production of a journal kept by 'Accuser-2' in 1996, arguing that the government is relying on selective excerpts to support its case while ignoring potentially exculpatory context in the rest of the journal. The letter also addresses disputes over the production of a pair of boots and original photographs, accusing the government of interfering with the defense's investigation and practicing 'selective ignorance.'
EFTA00014661.pdf
This document contains an email exchange between Ghislaine Maxwell's defense attorney, Laura Menninger, and US Prosecutors regarding Local Criminal Rule 23.1, which limits press statements. Menninger initially flags comments made by attorney Spencer Kuvin in 'The Sun' as a potential violation. The prosecution responds that Kuvin does not represent any trial witnesses, but counters that Maxwell's own appellate attorney, David Markus, may have violated the rule via statements to the 'NY Post'.
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-00008284.jpg
This document is an appearances page from a legal filing in Case 1:20-cr-00330-PAE, filed on December 9, 2021. It lists the names, roles, and affiliations of the attorneys and a paralegal representing the Plaintiff, and the attorneys representing the Defendant. A videographer is also noted as being present for the proceedings.
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-00001548.jpg
This document is a Notice of Appearance filed in the U.S. District Court for the Southern District of New York on July 8, 2020. Attorney Laura A. Menninger of the firm Haddon, Morgan and Foreman, P.C. officially enters her appearance as counsel for the defendant, Ghislaine Maxwell, in case number 20-CR-330-AJN.
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-00001233.jpg
This document is the cover page for a legal memorandum filed on February 23, 2021, in the Southern District of New York (Case 20 Cr. 330). It supports Ghislaine Maxwell's third motion for release on bail. The document lists the defense legal team, including Bobbi C. Sternheim, Christian R. Everdell, Jeffrey S. Pagliuca, and Laura A. Menninger.
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