HADDON OR A FOREMAN November VIA EMAIL United States Attorneys Office Southern District of New York I St Andrews Plaza New York NY Haddon Morgan and Foreman Jeffrey Pagliuca Eost lath Avenue Denver Co PH FX hmflaw corn Re United States Ghisiaine Maxwell Cr AJN Defendants Good Faith Non Frivolous Objections to Proffered Co Conspirator Hearsay Statements Dear Counsel Pursuant to the Courts November Order we write to note our good faith objections to certain categories of alleged co-conspirator hearsay statements and representative examples Regarding the first third and fourth designated categories there are two issues for conferral First we assume that these proffered statements are limited to those individuals specifically identified by the government as minor victims in the indictment or correspondence to defense counsel dated October There were many alleged minor victims in the Southern Florida state and federal investigations To the extent that the government intends to include statements made to other alleged minor victims not specifically identified Ms Statements made by Epstein to friends and Family of Minor Victims Statements made by CC to friends and Family of Minor Victims and Statements made by Jeffrey Epstein to the Minor Victims or in their presence November Page Maxwell objects In addition these categories do not contain any temporal limitations and we object to any statements allegedly made outside the dates of the alleged conspiracy Category Statements made by Jeffrey Epstein to his employees appears to primarily relate to statements that post-date any alleged conspiracy The first exemplar is a statement allegedly from Epstein to CC claiming that Ms Maxwell used to find girls for him This statement or statements like it cannot have been made either in the course of or in furtherance of any conspiracy at issue here and are no more than idle chatter United States Lieberman F.2d 2d challenged testimony smacked of nothing more than casual conversation about past events It is difficult to envision how it would have furthered the conspiracy Similarly the second example concerns direction from Epstein and CC to CC to help someone who was coming to take the computers Again this statement does not appear to be during or in furtherance of any conspiracy alleged in the indictment See Lutwak United States U.S Kruleivitch United States U.S We assume the third example relates to the time period alleged in the indictment To the extent it does not we object Best Regards Jeffrey Pagliuca
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