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hislaine Maxwell In Opposition to the Government's Motion for Detention EFTA00093089 cimil lyZ7lbifistuxtriitridcdniZAliPlOs%dV*719A)Pkje'hetffW1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. • • • • x 20 Cr. 330 (AJN) MEMORANDUM OF GHIS
e Mufti) Sates' Court of 5Appeats for the £ieconb (Circuit UNITED STATES OF AMERICA. Appellee, v. GHISLAINE MAXWELL, Appellant. On Appeal from the United States District Court for the Southern District of New York, 20-CR-330 (MN) Appellant Ghislaine Maxwell's Motion for Pretrial Release David Oscar Markus MARKUS/MOSS PL
of whom have foreign ties, are routinely granted bail so that they can effectively prepare for trial. Bernie Madoff. Harvey Weinstein. Bill Cosby. John Gotti. Marc Dreier. Dominique Strauss- Kahn. Ali Sadr. Adnan Khashoggi. Mahender Sabhnani. The list goes on and on. In each case, the court set reasonable
cuat. tRif3CSE• v Epstein and Maxwell (2017),4 - filID`Weet, DeSTROCTUDN O-- .4 In 2017, CARE-66; ?Kce..F.T.J.c:-Th - C.CEI fty fled a suit, in the United States District Court for the Southern District of ' New York, against Epstein and Maxwe lLhired-hes to give massages to ,-,: E • and late threat i . hannhei or dest
sex trafficking charges)._2711857[1861[1M He was jailed at the Metropolitan Correctional Center in New York City, which has held prisoners such as John Gotti, Joaquin "El Chapo" Guzman, and Paul Manafort.(1881N893 - cr_N-ree_t_E-c-niet r)ccef-ct--/ -"THEFT ACI51RNA Bt() Ce\I According to witnesses and s
1'1 nivOS Sa)eCta)t. - TeR e.cen v Epstein and Maxwell (2017) A - mnsweet. pes-rw a t C(\ Gr CARCOR PkoeFE6-1-S - PLY In 2017, filed a suit, in the United States District Court for the Southern District of New York, again Epstein and Maxwell, alleging that Maxwell hired her to give massages to Epstein and lat reatened to
icking charges,[27][185D86][187] He was jailed at the run Metropolitan Correctional Center in New York City, which has held . prisoners such as John Gotti, Joaquin "El Chapo" Guzman, and Paul manaforossliissi _ . _ rsc - -ThRELLECOcit PceeiSMI i Hen- - Aostrai FC, COV According to witnesses and
ll paying "millions".16±11 rn v Epstein and Maxwell (2017) ?1k- Mflswett. D esTRVatoN OT-- coRaerfZ Pkosreas - cod) PLY In 2017, filed a suit, in the United States District Court for the Southern District of New York, agait astein and Maxwell, alleging that Maxwell hired her to give massages to ,_.. Epstein and late tened
n sex trafficking ehargesirlPsltilmg.1871 He was jailed at the Metiopolitan Correctional Center in New York City, which has held prisoners such as John Gotti, Joaquin "El Chapo" Guzman, and Paul Manafortiggati91 According to witnesses and sources on the day of his arrest, about a dozen FBI agents forced
ell 2017) 4- elf9sWezt. neSTNCTIOP4 Cl- C-IRREeR iskesc-IS - col poi , "stet t cct oft, InceaTi -MEET --)ivEsr ittcr(oN In 2017, filed a suit, in the United States District Court for the Southern District of New York, agaVpstein and Maxwell, alleging that Maxwell hired her to give massages to _ Epstein and lat neatened to p
sex trafficking charges.trifilt013-18 He was jailed at the Metropolitan Correctional Center in New York City, which has held OP prisoners such as John Gotti, Joaquin "El Chapo" Guzman, and Paul Manafort (081189.1 filite-Eb•rateerlYie- f*Oett1Kri 'THEFT - A03-tRfti t.; Cc .J According to witnesses and
en NC* Sarah Ransoms v Epstein and Maxwell (2017) csik Mf tWeti, DeSTELW-11O (4 a- cAREER eKesm-crS cCM PLY In 2017, Sarah Ransome fled a suit, in the United States District Court for the Southern District of New York, ag t E stein and Maxwell, alleging that Maxwell hired her to ve massages to E. stein and lat Ica harm -
sex trafficking charges.(VB851[11161P 7 He was jailed at the Metropolitan Correctional Center in New York City, which has held prisoners such as John Gotti, Joaquin "El Chapo" Guzman, and Paul Manafort.V8M191 Wtr•SC -T-NrCaLiMIDee- PgoetSICIN *THEFT - ACCORPiLieti Coy According to witnesses and sourc
Entities connected to both the United States District Court and John Gotti

Jeffrey Epstein
PERSONthe Southern District
LOCATION
United States
LOCATION
Alexander Acosta
PERSONFBI
ORGANIZATION
Department of Justice
ORGANIZATION
Kenneth Marra
PERSON
Ghislaine Maxwell
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSON
George W. Bush
PERSONLeon Black
PERSONGerald Lefcourt
PERSON
Alan Dershowitz
PERSON
New York
LOCATION
Jay Lefkowitz
PERSON
Virginia Giuffre
PERSON
Scarlett Johansson
PERSON
Donald Trump
PERSON