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ne 29, 2020. a grand jury in the Southern District of New York returned a six-count Indictment against the Defendant, charging her with facilitating Jeffrey Epstein's sexual abuse of multiple minor victims between approximately 1994 and 1997. See Dkt. No. 1. On July 2, 2020, the Indictment was unsealed, and that
t 30 years, might flee to the United Kingdom or France if granted bail, despite the fact that she did not leave the country for nearly a year after Epstein's arrest. (Dkt. 22 at 6.) The government asserted in its reply brief that France "does not extradite its citizens to the United States pursuant to F
eve of the one-year anniversary of the arrest of Jeffrey Epstein, creating the misimpression that Ms. Maxw
l's mouth, which heightens her risk of contracting the deadly virus, which has now surged to 113 positive cases in the MDC. Further, Deputy Captain B. Houtz recently issued a memo stating that "[i]t has not been determined whether legal calls and legal visits will continue." As the Court is well aware,
Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &
Page: EFTA00015977 →record would readily support release on strict bail conditions, perhaps even on consent. But this is Ghislaine Maxwell, the apparent substitute for Jeffrey Epstein. So, instead, in its response the government urges the Court to disregard the significant additional evidence proffered to the Court and further arg
Page: EFTA00015981 →documentary corroboration referenced by the government—which are the same examples that the government touted at the initial bail hearing—pertain to Epstein, not Ms. Maxwell. The government concedes that government further states that (Gov. Mem. at II (emphasis added)). The (Id. (emphasis added)). Th
Page: EFTA00015982 →LP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &
Page: EFTA00016769 →record would readily support release on strict bail conditions, perhaps even on consent. But this is Ghislaine Maxwell, the apparent substitute for Jeffrey Epstein. So, instead, in its response the government urges the Court to disregard the significant additional evidence proffered to the Court and further arg
Page: EFTA00016773 →documentary corroboration referenced by the government—which are the same examples that the government touted at the initial hail hearing pertain to Epstein, not Ms. Maxwell. The government concedes that ." (Gov. Mem. at 11 (emphasis added)). The government further states that " I=1=1 ." (Id. (emphas
Page: EFTA00016774 →Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &
Page: EFTA00019291 →record would readily support release on strict bail conditions, perhaps even on consent. But this is Ghislaine Maxwell, the apparent substitute for Jeffrey Epstein. So, instead, in its response the government urges the Court to disregard the significant additional evidence proffered to the Court and further arg
Page: EFTA00019295 →documentary corroboration referenced by the government—which are the same examples that the government touted at the initial bail hearing—pertain to Epstein, not Ms. Maxwell. The government concedes that (Gov. Mem. at 11 (emphasis added)). The government further states that (Id. (emphasis added)). Th
Page: EFTA00019296 →Entities connected to both Jeffrey Epstein and B. Houtz

Ghislaine Maxwell
PERSON
United States
LOCATION
Michael Cohen
PERSON
Jean-Luc Brunel
PERSON
Denver
LOCATIONJeffrey Pagliuca
PERSON
United Kingdom
LOCATIONLaura Menninger
PERSONJulie
PERSONCohen & Gresser LLP
ORGANIZATION
Brady
PERSONBobbi C. Sternheim
PERSONMark S. Cohen
PERSONPretrial Services
ORGANIZATION
Christian R. Everdell
PERSONPretrial
ORGANIZATIONthe French Ministry of Justice
ORGANIZATIONDavid Perry
PERSONBAIL Mark S. Cohen
PERSON