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Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN OPPOSITION TO THE GOVERNMENT'S MOTION FOR DETENTION Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca (pro hac vice admission pending) Laura A. Menn
have remained committed to her because they do not believe the allegations against her, which do not match the person they have known for decades. The Government's Position. The government has the burden of persuasion in showing that detention is warranted, and that there are no conditions or combination of conditions t
Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN OPPOSITION TO THE GOVERNMENT'S MOTION FOR DETENTION Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca (pro hac vice admission pending) Laura A. Menn
have remained committed to her because they do not believe the allegations against her, which do not match the person they have known for decades. The Government's Position. The government has the burden of persuasion in showing that detention is warranted, and that there are no conditions or combination of conditions t
Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN OPPOSITION TO THE GOVERNMENT'S MOTION FOR DETENTION Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca (pro hac vice admission pending) Laura A. Menn
have remained committed to her because they do not believe the allegations against her, which do not match the person they have known for decades. The Government's Position. The government has the burden of persuasion in showing that detention is warranted, and that there are no conditions or combination of conditions t
Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN OPPOSITION TO THE GOVERNMENT'S MOTION FOR DETENTION Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca (pro hac vice admission pending) Laura A. Menn
have remained committed to her because they do not believe the allegations against her, which do not match the person they have known for decades. The Government's Position. The government has the burden of persuasion in showing that detention is warranted, and that there are no conditions or combination of conditions t
Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN OPPOSITION TO THE GOVERNMENT'S MOTION FOR DETENTION Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca (pro hac vice admission pending) Laura A. Menn
have remained committed to her because they do not believe the allegations against her, which do not match the person they have known for decades. The Government's Position. The government has the burden of persuasion in showing that detention is warranted, and that there are no conditions or combination of conditions t
. • • • • x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL JN OPPOSITION TO THE GOVERNMENT'S MOTION FOR DETENTION Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca (pro hoc vice admission pending) Laura A. Menninger HADDON
have remained committed to her because they do not believe the allegations against her, which do not match the person they have known for decades. The Government's Position. The government has the burden of persuasion in showing that detention is warranted, and that there are no conditions or combination of conditions t
Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN OPPOSITION TO THE GOVERNMENT'S MOTION FOR DETENTION Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca (pro hac vice admission pending) Laura A. Menn
have remained committed to her because they do not believe the allegations against her, which do not match the person they have known for decades. The Government's Position. The government has the burden of persuasion in showing that detention is warranted, and that there are no conditions or combination of conditions t
Entities connected to both R. Everdell and The Government's Position

Michael Cohen
PERSON
Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSONJeffrey Pagliuca
PERSONCohen & Gresser LLP
ORGANIZATION
United States
LOCATIONMark S. Cohen
PERSONSecond Circuit
ORGANIZATION
Denver
LOCATIONthe Southern District
LOCATION
United Kingdom
LOCATION
Southern District of New York
ORGANIZATION
Stephen Hawking
PERSON
Colorado
LOCATIONBoustani
PERSONPretrial Services
ORGANIZATIONKarni
PERSONCourtney Wild
PERSONFederal Bureau of Prisons
ORGANIZATION
Metropolitan Correctional Center
ORGANIZATION