731-02.pdf
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- pdf
- Source set
- house-oversight-doj
- Pages
- 3
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- Searchable text available
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- 0.9444318454346551
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Case 1:20-cr-00330-PAE Document 731-2 Filed 07/14/22 Pagelof3 PANISH SHEA & BOYLE LLP December 15, 2021 VIA EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: I am writing on behalf of witness Jane in regard to Ms. Maxwell's recent filing regarding her attorney Robert Glassman who represented her in her civil case against the Epstein Estate and Ms. Maxwell that settled over a year ago. Ms. Maxwell raises three areas that she wants to solicit testimony from Mr. Glassman. 1. The "Help her case" email Jane stands on the opposition she submitted on December 6, 2021 and the Government's opposition regarding that email. 2. The Lion King email As the Government points out, Jane was extensively cross-examined on this issue. Mr. Glassman would have nothing to add, and anything he could say would require him to disclose confidential information in violation of California Rule of Professional Conduct 1.6. 3. Settlement Demands to Ms. Maxwell and the EVCP 11111 Santa Monica Boulevard, Suite 700 * Los Angeles, California 90025 * 310.477.1700 phone * 310.477.1699 fax * www.psblaw.com DOJ-OGR-00011421
Case 1:20-cr-00330-PAE Document 731-2 Filed 07/14/22 PANTSH SHEA & The Honorable Alison J. Nathan BOYLE December 15, 2021 LLP Page 2 Ms. Maxwell would like to ask Mr. Glassman whether he made a $25 million demand to Ms. Maxwell to settle the civil case against her. It should be noted that defense counsel did not question Jane about this demand when they had a chance, so there is no impeachment value to anything Mr. Glassman could say. It should also be noted that Ms. Maxwell or Ms. Menninger (who represented Ms. Maxwell in the civil case), who are both already present in the courtroom, could testify about any such demand. So there is nothing Mr. Glassman could offer on this subject that would be probative and outweigh the risk o…
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