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amples of French courts deporting individuals who have lost French nationality following the commission of an offense. (Id. ¶ 21). Accordingly, Mr. Julie concludes: "Mt cannot have been the intention of French lawmakers that Article 696-4 be construed as meaning that a person who has lost French nati
R RAIL Bobbi C. Sternheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York NY 10011 Phone: 1IMI Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New Y Phone Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.0 150 East 10th Avenue Denve Attorneys for Gh
ce. The accompanying report of William Julie ("Julie Rep.") reviews the French extradition process as it would likely be applied to Ms. Maxwell. Mr. Julie is an expert on French extradition law who has handled extradition cases both within and outside the European Union and regularly appears as an ext
Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Ghislaine
ce. The accompanying report of William Julie ("Julie Rep.") reviews the French extradition process as it would likely be applied to Ms. Maxwell. Mr. Julie is an expert on French extradition law who has handled extradition cases both within and outside the European Union and regularly appears as an ext
Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Ghislaine
ce. The accompanying report of William Julie ("Julie Rep.") reviews the French extradition process as it would likely be applied to Ms. Maxwell. Mr. Julie is an expert on French extradition law who has handled extradition cases both within and outside the European Union and regularly appears as an ext
Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Denver, CO 80203 Phone: Bobbi C. Stemheim Law
ce. The accompanying report of William Julie ("Julie Rep.") reviews the French extradition process as it would likely be applied to Ms. Maxwell. Mr. Julie is an expert on French extradition law who has handled extradition cases both within and outside the European Union and regularly appears as an ext
suant to the conditions she has proposed. Dated: December 4, 2020 Respectfully submitted, /s/ Mark S. Cohen Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver,
amples of French courts deporting individuals who have lost French nationality following the commission of an offense. (Id. ¶ 21). Accordingly, Mr. Julie concludes: "[I]t cannot have been the intention of French lawmakers that Article 696-4 be construed as meaning that a person who has lost French na
E ON BAIL Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver,
adite Ms. Maxwell (Def. Mem., Ex. V at 2), the government attaches a letter from the French Ministry of Justice ("MOJ") that references neither Mr. Julie's report nor Ms. Maxwell, but states generally that the French Code of Criminal Procedure "absolutely prohibits" the extradition of a French nationa
Page: EFTA00016781 →iry. 10 EFTA00016782 --- PAGE BREAK --- Dated: December 18, 2020 Respectfully submitted, is/Marks Cohen Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver,
Page: EFTA00016783 →adite Ms. Maxwell (Def. Mem., Ex. V at 2), the government attaches a letter from the French Ministry of Justice ("MOJ") that references neither Mr. Julie's report nor Ms. Maxwell, but states generally that the French Code of Criminal Procedure "absolutely prohibits" the extradition of a French nationa
Page: EFTA00019303 →. 10 EFTA00019304 --- PAGE BREAK --- Dated: December 18, 2020 Respectfully submitted, /s/ Mark S. Cohen Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Ave
Page: EFTA00019305 →f the law. • The government's argument goes against the spirit of the law. • The government's argument is contradicted by precedent and case law. (Julie Opinion ¶¶ 6-26). 3 EFTA00031921 --- PAGE BREAK --- The language of the extradition treaty between the United States and France and the applica
Page: EFTA00031922 →rnment This memorandum was written pursuant to a request from Olivier Laude, a partner at the French firm Laude Esquier Champey acting on behalf of Cohen & Gresser LLP as counsel for Ms Ghislaine Maxwell. The request was made in the context of ongoing bail proceedings involving Ms Maxwell in the United States of A
Page: EFTA00031930 →Entities connected to both Julie and Cohen & Gresser LLP

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Michael Cohen
PERSONJeffrey Pagliuca
PERSONLaura Menninger
PERSON
Prince Andrew
PERSON
Denver
LOCATIONBobbi C. Sternheim
PERSON
Department of Justice
ORGANIZATIONMark S. Cohen
PERSON
United States
LOCATION
Julie K. Brown
PERSON
John F. Kennedy
PERSONR. Everdell
PERSON
Stephen Hawking
PERSONMORGAN & FOREMAN
ORGANIZATIONSecond Circuit
ORGANIZATION
United Kingdom
LOCATION
Marc Rich
PERSONthe Southern District
LOCATION