Denver, Colorado
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This document is a Certificate of Service filed on March 4, 2016, in a legal case (referenced by case numbers 1:15-cv-07433-RWS and 1:20-cr-00330-AJN). Attorney Sigrid S. McCawley certifies that she electronically filed a document and served it upon attorney Laura A. Menninger of Haddon, Morgan & Foreman, P.C. via the CM/ECF system. The document bears a Department of Justice Bates stamp.
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This document is a page from a legal filing, dated January 25, 2021, for Case 1:20-cr-00330-AJN. It lists contact information for two law firms, HADDON, MORGAN & FOREMAN P.C. and Law Offices of Bobbi C. Sternheim, identifying them as attorneys for Ghislaine Maxwell.
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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.
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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.
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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.
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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.
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This document is the signature page (page 36 of 37) of a legal filing from February 11, 2022, in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The defense team, including attorneys Everdell, Pagliuca, Menninger, and Sternheim, is requesting the court to vacate Maxwell's conviction, dismiss the S2 Indictment, and enter a judgment of acquittal under Rule 29 based on insufficient government proof.
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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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This page contains the conclusion and signature block of a legal motion filed on March 11, 2022, in the case against Ghislaine Maxwell. The document requests that the court vacate Maxwell's conviction and enter a judgment of acquittal. It lists the contact information for her legal defense team, including Christian R. Everdell, Jeffrey S. Pagliuca, Laura A. Menninger, and Bobbi C. Sternheim.
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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.
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This is the final page (Conclusion) of a legal motion filed on February 23, 2021, in the case of United States v. Ghislaine Maxwell. Her defense team argues that additional proposed conditions—including renouncing foreign citizenship and asset monitoring—should satisfy the Bail Reform Act. The document lists the defense attorneys representing Maxwell.
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This document is the second page of a legal filing (Document 145) in case 1:20-cr-00330-AJN, filed on February 4, 2021. It lists the contact information for the law firms Haddon, Morgan & Foreman P.C. and the Law Offices of Bobbi C. Sternheim, identifying them as the attorneys representing Ghislaine Maxwell.
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This document is the cover page for a legal memorandum filed on February 23, 2021, in the Southern District of New York. It supports Ghislaine Maxwell's third motion for release on bail in case 20 Cr. 330 (AJN). The document lists the defense legal team, including attorneys from three different law firms based in New York and Colorado.
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This document is the conclusion of a legal motion filed on January 25, 2021, on behalf of Ghislaine Maxwell. Her attorneys request that the Court either strike all references to 'Accuser-3' from specific paragraphs of the indictment or compel the government to provide advance notice before introducing any evidence related to that accuser. The document is signed by her legal team from three different law firms.
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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.
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This document is a page from a legal filing in Case 1:20-cr-00330-AJN, filed on February 4, 2021. It identifies Laura A. Menninger and Bobbi C. Sternheim as the attorneys representing Ghislaine Maxwell. The document provides the names, law firms, addresses, and phone numbers for both attorneys.
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An email chain from August 2012 between Barbro Ehnbom and Jeffrey Epstein (using the alias jeevacation). Epstein explicitly asks Ehnbom for a 'wife choice' for the year, to which she replies with the name and photo of a 'brainy and sensual' female project manager. The thread also discusses an invitation to Bill Clinton, a fundraiser for Congresswoman Diana deGette, and mutual friends including 'Goldsamt' in Miami.
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This document is a page from a 2005 BYU Law Review article attached as an exhibit in a House Oversight investigation, bearing the name of Epstein attorney David Schoen. The text discusses the legal limitations of the Victims' Rights Act and the Crime Victims' Rights Act, specifically analyzing the *United States v. McVeigh* (Oklahoma City bombing) case where victims were denied certain rights despite statutory protections. It argues that statutory measures often fail due to judicial interpretation and bureaucratic inertia, leading advocates to push for a constitutional amendment.
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This document is a communication log from May 3, 2019, between 'e:jeeitunes@gmail.com' (an alias for Jeffrey Epstein) and a redacted individual. They are coordinating travel logistics, with Epstein proposing a flight to Arizona on the 8th or 9th followed by a connection to Europe via Dallas, Denver, or LA. The redacted individual mentions needing to check their schedule ('sked') and requiring a red-eye flight after 'we film on Monday,' suggesting they are involved in a production or media event.
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This document is page 2 of a legal filing arguing to quash a subpoena issued by the Defendant to 'Jane Doe No. 3' (a non-party witness/victim). The text details a 'media blitz' by the Defendant in early 2015, citing interviews with CNN, ABC, Newsmax, and the NY Daily News where the Defendant threatened Jane Doe No. 3 with jail for perjury, called her names, and stated intentions to sue her for defamation. The filing argues these actions constitute abuse of subpoena power and intimidation.
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This document is a Motion to Quash filed on April 9, 2015, in Broward County, Florida, on behalf of 'Jane Doe No. 3' in the defamation case of Edwards & Cassell v. Dershowitz. Jane Doe No. 3 argues that the subpoena served by Alan Dershowitz is oppressive and intended to harass her. The motion cites a recent public statement by Dershowitz claiming he found her hiding in Colorado and intends to send her to jail.
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This document page discusses the banning of a publication titled "Texas Dept. of Criminal Justice, Publication Review" from Death Row due to fears it would cause prison disruption. It specifically cites two passages as problematic: an excerpt from Jackie Robinson's autobiography expressing anger at racism, and a historical account of race riots following Jack Johnson's boxing victory over Jim Jeffries.
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This document appears to be a page from a book or narrative statement included in House Oversight Committee evidence (marked 015064). It discusses the 'hypocrisy' of politicians and clergy regarding abortion access, citing specific instances where they utilized services despite public opposition. The text features a narrator, likely the editor of the magazine 'The Realist,' describing how they began referring women to a 'Dr. Spencer' after publishing an interview with him. It also references a 2013 legal argument by Catholic hospitals regarding fetal personhood. While part of a larger cache that may involve Epstein, this specific page focuses on historical reproductive rights advocacy and Dr. Spencer.
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This document is page 82 of a Cannabis Investment Report produced by Ackrell Capital in December 2017. The text analyzes the legal and financial complexities of the cannabis industry, specifically focusing on the inability to file for federal bankruptcy protection and the tax implications of IRC Section 280E, which limits business deductions for entities trafficking in controlled substances. The document bears a House Oversight Committee Bates stamp, suggesting it was part of a larger congressional inquiry, though the specific page content does not mention Jeffrey Epstein.
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This document is page 58 of a Cannabis Investment Report created by Ackrell Capital, LLC in December 2017. It analyzes the 'Business Solutions Outlook' and 'Digital Media' segments of the cannabis industry, discussing market opportunities for software, big data, and media platforms that do not directly handle the plant. The document bears a 'HOUSE_OVERSIGHT_024694' Bates stamp, indicating it was part of a document production to the House Oversight Committee, likely related to financial probes involving banks or individuals connected to the investigation.
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