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efta-efta00040124DOJ Data Set 9Other

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From: '• To: Jeff Pagliuca Cc: "ceverdel C (USANYS)" Subject: RE: Subpoena for Date: Thu, 18 Nov 2021 02:27:03 +0000 Attachments: 2021.11.14 Mm forOrderAuthaSubPursm_to_F.R.Crim.P_17(c) 2021.11.14_Ex._1.pdf Inline-Images: image001.gif; image002.jpg Thanks, Jeff. Brian, in light of Jeff's email, attached is the unredacted defense motion. i ns hanks From: Jeff Pagliuca Sent: Wednesday, November 17, 2021 9:07 PM To: Brian Burns Cc: ceverdel Subject: [EXTERNAL] Re: Subpoena for >; Laura Menninger Brian, I believe that we were waiting for any proposed redactions from the government. We have no problem with the government sending you a copy of the motion. If the government does not object, we will send it. However, the government has designated every production confidential, subject to its protective order, and the motion contains information designated as confidential. Accordingly, we will defer to it as to what you should receive. Best Regards, Jeffrey S. Pagliuca.

Date
Unknown
Source
DOJ Data Set 9
Reference
EFTA 00040124
Pages
2
Persons
2
Integrity

Summary

From: '• To: Jeff Pagliuca Cc: "ceverdel C (USANYS)" Subject: RE: Subpoena for Date: Thu, 18 Nov 2021 02:27:03 +0000 Attachments: 2021.11.14 Mm forOrderAuthaSubPursm_to_F.R.Crim.P_17(c) 2021.11.14_Ex._1.pdf Inline-Images: image001.gif; image002.jpg Thanks, Jeff. Brian, in light of Jeff's email, attached is the unredacted defense motion. i ns hanks From: Jeff Pagliuca Sent: Wednesday, November 17, 2021 9:07 PM To: Brian Burns Cc: ceverdel Subject: [EXTERNAL] Re: Subpoena for >; Laura Menninger Brian, I believe that we were waiting for any proposed redactions from the government. We have no problem with the government sending you a copy of the motion. If the government does not object, we will send it. However, the government has designated every production confidential, subject to its protective order, and the motion contains information designated as confidential. Accordingly, we will defer to it as to what you should receive. Best Regards, Jeffrey S. Pagliuca.

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Text extracted via OCR from the original document. May contain errors from the scanning process.
From: '• To: Jeff Pagliuca Cc: "ceverdel C (USANYS)" Subject: RE: Subpoena for Date: Thu, 18 Nov 2021 02:27:03 +0000 Attachments: 2021.11.14 Mm forOrderAuthaSubPursm_to_F.R.Crim.P_17(c) 2021.11.14_Ex._1.pdf Inline-Images: image001.gif; image002.jpg Thanks, Jeff. Brian, in light of Jeff's email, attached is the unredacted defense motion. i ns hanks From: Jeff Pagliuca Sent: Wednesday, November 17, 2021 9:07 PM To: Brian Burns Cc: ceverdel Subject: [EXTERNAL] Re: Subpoena for >; Laura Menninger Brian, I believe that we were waiting for any proposed redactions from the government. We have no problem with the government sending you a copy of the motion. If the government does not object, we will send it. However, the government has designated every production confidential, subject to its protective order, and the motion contains information designated as confidential. Accordingly, we will defer to it as to what you should receive. Best Regards, Jeffrey S. Pagliuca. On Nov 17, 2021, at 7:58 PM, Brian Burns wrote: Defense counsel — Would you please provide us a copy of your motion seeking the issuance of this subpoena? We haven't seen a copy. Thank you. Brian T. Burns Smith Villazor LLP 250 West 55th Street, 30th Floor New York, New York 10019 Office Direct Mobile EFTA00040124 From: Christian Everdell Sent: Tuesday, November 16, 2021 8:48 PM To: Patrick Smit Cc: Jeff Pa liuca de; (USANYS) Subject: [EXTERNAL EMAIL] Subpoena fort Brian Burns Laura Menninger BOBBI C STERNHEIM Counsel — Attached please find the signed subpoena for Regards, Christian R Everdell COHEN & GRESSER LLP 800 Third Avenue New York. NY 10022 www.cohengresser.com I view bio New York I Paris I Washington DC I London Please acknowledge receipt. CONFIDENTIALITY NOTICE: The information contained in this e-mail may be confidential and/or privileged. This e-mail is intended fo be reviewed initially by only the individual named above. If the reader of this e-mail is not the intended recipient or a representative of the intended recipient. you are hereby notified that any review. dissemination or copying of this e-mail or the information contained herein is prohibited. If you have received this e-mail in error. please immediately notify the sender by telephone and permanently delete this e-mail. Thank you. PRIVACY: A complete copy of our privacy policy can be viewed al: httpsiAvww.cohenoressercom/privacK-policx EFTA00040125

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Related Documents (6)

Court UnsealedLegal FilingUnknown

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Ghislaine Maxwell's defense team filed a notice of motion to dismiss the superseding indictment, alleging it was obtained in violation of the Sixth Amendment. The motion is part of the pretrial proceedings in the case against Maxwell. Oral argument has been requested.

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Court UnsealedLegal FilingUnknown

Court Filing: 123

Ghislaine Maxwell's defense team filed a motion to dismiss Counts One through Four of the superseding indictment for lack of specificity. The motion was filed on January 25, 2021, in the United States District Court for the Southern District of New York. The defense team is represented by multiple attorneys from different law firms.

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Court UnsealedLegal FilingUnknown

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Ghislaine Maxwell's defense team filed a motion to dismiss either Count One or Count Three of the superseding indictment, arguing that they are multiplicitous. The motion was filed on January 25, 2021, in the United States District Court for the Southern District of New York. The defense team is represented by multiple attorneys from different law firms.

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Court UnsealedLegal FilingUnknown

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Ghislaine Maxwell's defense team files a motion to suppress evidence obtained from a government subpoena and to dismiss Counts Five and Six of the indictment, citing the Due Process Clause. The motion is supported by a memorandum of law and exhibits. The defense attorneys representing Maxwell are listed, along with their contact information.

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Court UnsealedLegal FilingUnknown

Court Filing - Notice of Electronic Filing: 21-2

The document is a notice of electronic filing from the US District Court, Southern District of New York, indicating that the appeal record in USA v. Maxwell has been transmitted to the US Court of Appeals. It includes details about the case, the charges against Ghislaine Maxwell, and the attorneys involved. The case involves charges of conspiracy, enticement, and transportation of minors for illegal sex acts, among others.

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Dept. of JusticeOtherUnknown

Stipulation Agreement: doj-ogr-00015165

The document is a stipulation agreement between the prosecution and defense in the case against Ghislaine Maxwell, agreeing to admit Defense Exhibit A1 into evidence at trial, dated December 17, 2021.

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