Epstein Secrets

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 Maxwell EFTA0006571

tian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C

Her Arrest 18 1. Ms. Maxwell Was Trying to Protect Herself from a Media Frenzy and from Physical Threats 18 2. Ms. Maxwell's Counsel Was in Regular Contact with the Government Prior to Her Arrest 22 3. Ms. Maxwell Did Not Try to Avoid Arrest, Nor Was She "Good At" Hiding 23 D. Ms. Maxwell Has Wai

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 Maxwell EFTA0015451

tian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C

Her Arrest 18 1. Ms. Maxwell Was Trying to Protect Herself from a Media Frenzy and from Physical Threats 18 2. Ms. Maxwell's Counsel Was in Regular Contact with the Government Prior to Her Arrest 22 3. Ms. Maxwell Did Not Try to Avoid Arrest, Nor Was She "Good At" Hiding 23 D. Ms. Maxwell Has Wai

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 Offices of Bobbi C. Stemheim New York, NY 10011

ESSER LLP New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C

8 1. Ms. Maxwell Was Trying to Protect Herself and Her Family from a Media Frenzy and from Physical Threats 18 2. Ms. Maxwell's Counsel Was in Regular Contact with the Government Prior to Her Arrest 22 3. Ms. Maxwell Did Not Try to Avoid Arrest, Nor Was She "Good At" Hiding 23 D. Ms. Maxwell Has Wai

rd Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C

IN SUPPORT OF HER RENEWED MOTION FOR BAIL 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, CO 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemhe

ent Before Her Arrest 18 1. Ms. Maxwell Was Trying to Protect Herself a Media Frenzy and from Physical Threats 2. Ms. Maxwell's Counsel Was in Regular Contact with the Government Prior to Her Arrest from 3. Ms. Maxwell Did Not Try to Avoid Arrest, Nor Was She "Good At" Hiding D. Ms. Maxwell Has Waive