EFTA00023329.pdf

"We write on behalf of our client, Ghislaine Maxwell"

"Christian It. Everdell ... COHEN & GRESSER LLP"

"Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)"

"a defamation suit brought against Ms. Maxwell in 2015 by one of Epstein's alleged victims ('Accuser-1')"

"The Honorable Alison J. Nathan United States District Court Southern District of New York ... Re: United States v. Ghislaine Maxwell"

"the government's October 6, 2020 letter requesting the Court's permission to delay the disclosure of photographs and documents"

"Accuser-1, in turn, claimed that these statements were defamatory and sued Ms. Maxwell. ... [Accuser-1] v. Maxwell, 15-CV-07433"

"a defamation suit brought against Ms. Maxwell in 2015 by one of Epstein's alleged victims ('Accuser-1')"

"challenging the validity of Epstein's Non-Prosecution Agreement executed in 2007"

"Case 1:20-cr-00330-AJN Document 64 Filed 10/14/20 ... existing case against Ms. Maxwell"

"Sincerely, /s/ Christian Everdell Christian R. Everdell COHEN & GRESSER LLP"

"Case 1:20-cr-00330-AJN Document 64 ... The Honorable Alison J. Nathan"

"Christian R. Everdell COHEN & GRESSER LLP"

"The Honorable Alison J. Nathan October 14, 2020 ... Sincerely, /s/ Christian Everdell"

"individuals who claim to have been assaulted by Epstein after 1997... Epstein's scheme to recruit and sexually abuse underage girls"

"one of Epstein's alleged victims ('Accuser-1')"

"claim that she knew about it in any way. That bolsters Ms. Maxwell's defense that she was not aware of either Epstein's scheme"

"the government's theory of the charges in the Indictment and must be disclosed pursuant to the government's Brady obligations."

"cc: Mark S. Cohen, Esq. Jeff Pagliuca, Esq. Laura Menninger, Esq. Bobbi C. Stemheim, Esq."

"Maxwell's role as one of the main women who Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator and participan"