Epstein Secrets

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

United States v. DiGiacomo, 746 F. Supp. 1176 (D. Mass. 1990) 14 United States v. Dominguez, 783 F.2d 702 (7th Cir. 1986) 10 United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009) 21 United States v. English, 629 F.3d 311 (2d Cir. 2011) 10, 11 ii EFTA00093092 cQ@&€i 'Is.rafåeffiAl,f

e 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 conditions o

the individuals referred to in paragraph (7), supra, elects to file suit pursuant to IS U.S.C. § 2255, Epstein will not contest the jurisdiction of the United States District Court for the Southern District of Florida over his person and/or the subject matter, and Epstein waives his right to contest liability and also waives h

ffective in meeting those goals in many prominent cases prosecuted in our Circuit, including cases against defendants as infamous as Bernie Madoff, Marc Dreier and David Brooks. To be clear, defense counsel are fully confident Mr. Epstein will appear as required without resort to this measure. And we under

s v. Esposito, 309 F. Supp. 3d 24 (S.D.N.Y. 2018); United States v. Seng, No. 15-CR-706, 2017 WL 2693625 (S.D.N.Y. Oct. 23, 2015); United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009); United States v. Madoff, 586 F. Supp. 2d 240 (S.D.N.Y. 2009); United States v. Schlegel, No. 06-CR-550, 2008

the individuals referred to in paragraph (7), supra, elects to file suit pursuant to IS U.S.C. § 2255, Epstein will not contest the jurisdiction of the United States District Court for the Southern District of Florida over his person and/or the subject matter, and Epstein waives his right to contest liability and also waives h

ffective in meeting those goals in many prominent cases prosecuted in our Circuit, including cases against defendants as infamous as Bernie Madoff, Marc Dreier and David Brooks. To be clear, defense counsel are fully confident Mr. Epstein will appear as required without resort to this measure. And we under

s v. Esposito, 309 F. Supp. 3d 24 (S.D.N.Y. 2018); United States v. Seng, No. 15-CR-706, 2017 WL 2693625 (S.D.N.Y. Oct. 23, 2015); United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009); United States v. Madoff, 586 F. Supp. 2d 240 (S.D.N.Y. 2009); United States v. Schlegel, No. 06-CR-550, 2008