The provided document is a compilation of excerpts from two different court filings. The first is an...

Mixed court documents: 544

The provided document is a compilation of excerpts from two different court filings. The first is an affidavit from David Parse regarding juror misconduct during his trial, while the second is a letter from Jeffrey S. Pagliuca to Judge Alison J. Nathan discussing the anticipated testimony of attorneys Jack Scarola, Brad Edwards, and Robert Glassman in the trial of Ghislaine Maxwell.

COHEN & GRESSER LLP

COHEN & GRESSER LLP December 10, 2021 BY EMAIL. 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, S2 20 Cr. 330 (AJN) Dear Counsel: Pursuant to the Court's Order dated June 2, 2021 (Dkt. 297), we write to provide the government with the list of potential defense witnesses. Included on the list are three attorneys: Brad Edwards, Robert Glassman, and Jack Scarola. Pursuant to the Court's instruction, we will brief any privilege issues to the Court before offering their testimony. We would also like the opportunity to confer about stipulations concerning their testimony and the testimony of other witnesses. Finally, we reserve the right to add or substitute witnesses as we further define the defense case. 1. • 2. 3. 4. 5. 6. 7. 8. Task Force Office 9. Lucy Mary Clive 10. Dr. Park Dietz 2063779.1 EFTA00156482 December 10, 2021 Page 2 11. 12. 13. Brad Edwards (atto

[REDACTED - Survivor] Deposition May 2016

Case Document 1090-32 Filed 07/30/20 Page 1 of 89 EXHIBIT Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 2 of 89 GIUFFRE VS. MAXWELL Deposition [REDACTED - Survivor] 05/03/2016 _______________________________________________________________________ Agren Blando Court Reporting & Video, Inc. 216 16th Street, Suite 600 Denver Colorado, 80202 303-296-0017 Agren Blando Court Reporting & Video, Inc. Page 3 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 1 IN THE UNI

EFTA00018441

Court Filing: 545

The US Government filed a letter opposing Ghislaine Maxwell's request to call victim lawyers Jack Scarola, Brad Edwards, and Robert Glassman as witnesses, arguing that their testimony is irrelevant and would compromise attorney-client privilege. The Government contends that the victims themselves have already testified and been cross-examined, making the lawyers' testimony unnecessary. The court must decide whether to allow the defendant to call these lawyers as witnesses.

Giuffre Exhibits

Case 18-2868, Document 286, 08/09/2019, 2628248, Pagel of 55 EXHIBIT Case 18-2868, Document 286, 08/09/2019, 2628248, Page2 of 55 United States District Court Southern District Of New York --------------------------------------------------X Plaintiff, v. Ghislaine Maxwell, Defendant. -----------------------------------------------X ............................................... Virginia L. Giuffre, 15-cv-07433-RWS DEFENDANT GHISLAINE MAXWELL’S INITIAL F.R.C.P. 26(a)(1)(A) DISCLOSURES P