EFTA00083886.pdf

From: To: Jeff Pagliuc Cc: Nicole Simmons Subject: RE: Maxwell Date: Mon, 15 Jul 2019 20:18:39 +0000 Importance: Normal Jeff, We haven't spoken to Mark and hadn't heard from you that our call was canceled. Why don't you all let us know when you want to reschedule for, and with whom, and we'll go from there. thanks, From: Jeff Pagliuc. Sent: Monday, July 15, 2019 16:15 To: Cc: Nicole Subject: Re: Maxwell < Sorry I missed your call. I had to travel to North Carolina over the weekend to assist with some family issues. I am on my way back to Denver now. I have a court appearance in Aspen, Colorado tomorrow and should have quite a bit of phone availability during the drive. I assume Mark updated you on our status and am happy to discuss further when I am available. Jeff On Jul 9, 2019, at 7:36 PM, Jeff, wrote: You're absolutely correct and I'm sorry for the delay. Attached please find the form proffer letter, as discussed. And it is on our calendar to have a call on this Thursday the 11th, 4 p.m. your time (and 6 p.m. our time). Please let us know if it would be useful to chat in the interim—we're happy to, if so—and we look forward to being in touch soon. thank you, From: Jeff Pagliuca Sent: Tuesday, July 09, 2019 18:56 To: Cc: Nicole Simmons Subject: RE: Maxwell EFTA00083886 Hello, I expect you all have been busy in the last few days. When we spoke yesterday I understood that you would be sending a form proffer letter for my review. I would like to discuss the document with my client as soon as possible to keep the process moving. When you get a chance please send the draft and I will hopefully be in a position to discuss a potential proffer metting during our next call which I think is scheduled for 7-11 at 4pm my time. Best Regards, Jeff <image001.jpg> Jeffrey S. Pagliuca Haddon, Morgan and Foreman, P.C. ISO East 10th Avenue Denver, Colorado 80203 Main 303.831.7364 FX 303.832.2628 www. m aw.com CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may contain information that is confidential or legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this transmission in error, please notify the sender by telephone or return e-mail and delete the original transmission and its attachments without reading or saving it in any manner. Thank you From: ) [mailto: Sent: Sunday, July 7, 2019 1:46 PM To: Jeff Pagliuca Cc: Nicole Simmons; Subject: RE: Maxwell Jeff, Thanks for speaking with me this afternoon. I've copied my colleagues, you have everyone's contact information. and so that In terms of scheduling a call tomorrow, we are going to be tied up in the morning, and the afternoon is a bit uncertain given that we are not sure yet of the timing of the presentment for Mr. Epstein. I think it would make sense to plan for a call at 4, and we can let you know if we need to reschedule, if that's alright with you. Attached is the subpoena for Ms. Maxwell. The indictment is currently under seal, but we anticipate that it will be unsealed tomorrow morning and publicly available. Please let us know tomorrow if you have any difficulty and we can certainly send you a copy. Thanks very much, and looking forward to discussing further tomorrow. Assistant United States Attorney Southern District of New York One Saint Andrew's Plaza New York, NY 10007 EFTA00083887 From: Jeff Pagliuca Sent: Sunday, July 7, 2019 3:09 PM To: Cc: Nicole Simmons < Subject: Maxwell Dear M, It was a pleasure talking to you today. As we discussed, I am authorized to accept service of the subpoena for testimony issued to Ms. Maxwell by the Grand Jury, SDNY. I expect that we will need to coordinate a mutually convenient time to either appear or proffer, either in advance or in lieu of any testimony. I will be in court tomorrow morning and afternoon, so I have a small window to discuss the matter- probably between 11am and noon and then again at around 4pm my time which is 2 hrs. earlier than the East Coast. My staff will attempt to obtain a copy of the Epstein indictment as soon as it is publicly available. In my experience this can sometimes be difficult so If it is not an inconvenience perhaps you could email the indictment along with the subpoena and waiver. Best Regards, Jeff Jeffrey S. Pagliuca Haddon, Morgan and Foreman, P.C. 150 East 10th Avenue <image002.jpg> Denver, Colorado 80203 Main 303.831.7364 FX 303.832.2628 .00 CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may contain information that is confidential or legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that you must not read this transmission and that any disclosure, copying, printing, distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this transmission in error, please notify the sender by telephone or return e-mail and delete the original transmission and its attachments without reading or saving it in any manner. Thank you <blank proffer agreement.pdf> EFTA00083888