Epstein Secrets

d be limited to appearances in Court, meetings with 5 EFTA00013311 --- PAGE BREAK --- counsel, medical visits, and upon approval by the Court or Pretrial Services. Id. at 2-3. Furthermore, the Defendant would have on-premises security guards that she would pay for who would prevent her from leaving the reside

he evidence of a lack of candor is, if anything, stronger now than in July 2020, as it is clear to the Court that the Defendant's representations to Pretrial Services were woefully incomplete. That lack of candor raises significant concerns as to whether the Court has now been provided a full and accurat

e defendant has been indicted, there will be no preliminary hearing, and that takes us to the question of bail. In that regard, I have received the Pretrial Services report. I have also received a letter from the SOUTHERN DISTRICT REPORTERS. P.C. EFTA00015609 --- PAGE BREAK --- j782epsC kjc 4 5 6

fendant, he simply cannot reasonably be expected to appear in court if he is granted bail. Accordingly, the government joins the recommendation of Pretrial Services that the defendant be detained pending trial for a number of reasons. Starting with the conduct alleged, the defendant is charged with trafficking

e defendant has been indicted, there will be no preliminary hearing, and that takes us to the question of bail. In that regard, I have received the Pretrial Services report. I have also received a letter from the SOUTHERN DISTRICT REPORTERS, P.C. EFTA00015664 --- PAGE BREAK --- j782epsC kjc 4 5 6

fendant, he simply cannot reasonably be expected to appear in court if he is granted bail. Accordingly, the government joins the recommendation of Pretrial Services that the defendant be detained pending trial for a number of reasons. Starting with the conduct alleged, the defendant is charged with trafficking

address the merits, the government attempts to dismiss the significance of Ms. Maxwell's relationship with her spouse, noting that Ms. Maxwell told Pretrial Services that she was in the process of getting a divorce and that her spouse did not step forward as a co-signer at the initial bail hearing. (Id.

rincipal reasons for denying bail. Rather than question the report itself, the government attempts to argue that Ms. Maxwell deceived the Court and Pretrial Services about her assets. (Gov. Mem. at 22-23). 5 EFTA00016777 --- PAGE BREAK --- The report shows nothing of the sort. Ms. Maxwell, who was sitting in

ted to the Southern and Eastern Districts of New York; (iii) surrender of all travel documents with no new applications; (iv) strict supervision by Pretrial Services; (v) home confinement at a residence in the Southern District of New York with electronic GPS monitoring; (vi) visitors limited to Ms. Maxwell's imm

continue to need security guards to protect her upon release. Under the circumstances, if the Court requires it, the security guards could report to Pretrial Services.16 10 In United States v. Houston!, 932 F.3d 79 (2d Cir. 2019), the Second Circuit curtailed the circumstances under which a court can gra

address the merits, the government attempts to dismiss the significance of Ms. Maxwell's relationship with her spouse, noting that Ms. Maxwell told Pretrial Services that she was in the process of getting a divorce and that her spouse did not step forward as a co-signer at the initial bail hearing. (Id.

rincipal reasons for denying bail. Rather than question the report itself, the government attempts to argue that Ms. Maxwell deceived the Court and Pretrial Services about her assets. (Gov. Mem. at 22-23). 5 EFTA00019299 --- PAGE BREAK --- The report shows nothing of the sort. Ms. Maxwell, who was sitting in