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ave neither met nor spoken to her. She has been depicted as a cartoon-character villain in an attempt to turn her into a substitute replacement for Jeffrey Epstein. Yet, Ms. Maxwell is determined — and welcomes the opportunity — to face her accusers at trial and clear her name. The additional proposed bail con
urn her into a substitute replacement for Jeffrey Epstein. Yet, Ms. Maxwell is determined — and welcomes t
heim Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &
flee. The Court should therefore grant bail under the proposed conditions so that Ms. Maxwell can adequately prepare for trial. 3 EFTA00077265 The Proposed Additional Bail Conditions Will Reasonably Assure Nis. \ la kV% CH'S Appearance in Court As set forth above, Ms. Maxwell now proposes two additional restrictions that elimina
ave neither met nor spoken to her. She has been depicted as a cartoon-character villain in an attempt to turn her into a substitute replacement for Jeffrey Epstein. Yet, Ms. Maxwell is determined — and welcomes the opportunity — to face her accusers at trial and clear her name. The additional proposed bail con
urn her into a substitute replacement for Jeffrey Epstein. Yet, Ms. Maxwell is determined — and welcomes t
Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &
flee. The Court should therefore grant bail under the proposed conditions so that Ms. Maxwell can adequately prepare for trial. 3 EFTA00083714 The Proposed Additional Bail Conditions Will Reasonably Assure Nis. \ la kV% CH'S Appearance in Court As set forth above, Ms. Maxwell now proposes two additional restrictions that elimina
ave neither met nor spoken to her. She has been depicted as a cartoon-character villain in an attempt to turn her into a substitute replacement for Jeffrey Epstein. Yet, Ms. Maxwell is determined — and welcomes the opportunity — to face her accusers at trial and clear her name. The additional proposed bail con
urn her into a substitute replacement for Jeffrey Epstein. Yet, Ms. Maxwell is determined — and welcomes t
LP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &
flee. The Court should therefore grant bail under the proposed conditions so that Ms. Maxwell can adequately prepare for trial. 3 EFTA00083703 The Proposed Additional Bail Conditions Will Reasonably Assure Nis. \ la kV% CH'S Appearance in Court As set forth above, Ms. Maxwell now proposes two additional restrictions that elimina
ave neither met nor spoken to her. She has been depicted as a cartoon-character villain in an attempt to turn her into a substitute replacement for Jeffrey Epstein. Yet, Ms. Maxwell is determined — and welcomes the opportunity — to face her accusers at trial and clear her name. The additional proposed bail con
urn her into a substitute replacement for Jeffrey Epstein. Yet, Ms. Maxwell is determined — and welcomes t
Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &
flee. The Court should therefore grant bail under the proposed conditions so that Ms. Maxwell can adequately prepare for trial. 3 EFTA00083792 The Proposed Additional Bail Conditions Will Reasonably Assure Nis. \ la kV% CH'S Appearance in Court As set forth above, Ms. Maxwell now proposes two additional restrictions that elimina
ave neither met nor spoken to her. She has been depicted as a cartoon-character villain in an attempt to turn her into a substitute replacement for Jeffrey Epstein. Yet, Ms. Maxwell is determined — and welcomes the opportunity — to face her accusers at trial and clear her name. The additional proposed bail con
urn her into a substitute replacement for Jeffrey Epstein. Yet, Ms. Maxwell is determined — and welcomes t
heim Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &
flee. The Court should therefore grant bail under the proposed conditions so that Ms. Maxwell can adequately prepare for trial. 3 EFTA00090992 The Proposed Additional Bail Conditions Will Reasonably Assure Nis. \ la kV% CH'S Appearance in Court As set forth above, Ms. Maxwell now proposes two additional restrictions that elimina
ave neither met nor spoken to her. She has been depicted as a cartoon-character villain in an attempt to turn her into a substitute replacement for Jeffrey Epstein. Yet, Ms. Maxwell is determined — and welcomes the opportunity — to face her accusers at trial and clear her name. The additional proposed bail con
urn her into a substitute replacement for Jeffrey Epstein. Yet, Ms. Maxwell is determined — and welcomes t
heim Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &
flee. The Court should therefore grant bail under the proposed conditions so that Ms. Maxwell can adequately prepare for trial. 3 EFTA00102092 The Proposed Additional Bail Conditions Will Reasonably Assure Nis. \ la kV% CH'S Appearance in Court As set forth above, Ms. Maxwell now proposes two additional restrictions that elimina
ake personal calls, and the opportunity to exercise and shower. Clearly, this was an effort to avoid a recurrence of the BOP's negligence regarding Jeffrey Epstein's death. Contrary to the way she is hyper-monitored, Ms. Maxwell is classified with the standard CC I-Mh designation: inmate with no significant ment
s persuasively argued that the Non-Prosecution Agreement entered into by Jeffrey Epstein in 2007, which immunizes "any potential co-conspirators of Epstein," bars Ms. Maxwell's prosecution in this case, and that the counts charging her with alleged sexual abuse are time-barred. The government's respon
LP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &
ions so that Ms. Maxwell can adequately prepare for trial. 3 EFTA00093354 Glasza2207a000113000It loaLfitekseit fat 1 ,Rifellfa2,23ftePabef43219 The Proposed Additional Bail Conditions Will Reasonably Assure Ms. Maxwell's Appearance in Court As set forth above, Ms. Maxwell now proposes two additional restrictions that eliminate a
Entities connected to both Jeffrey Epstein and The Proposed Additional Bail Conditions

Richard Kahn
PERSON
Ghislaine Maxwell
PERSON
John F. Kennedy
PERSON
United States
LOCATION
Michael Cohen
PERSON
Denver
LOCATION
Colorado
LOCATIONJeffrey Pagliuca
PERSON
United Kingdom
LOCATIONCohen & Gresser LLP
ORGANIZATIONBobbi C. Sternheim
PERSONthe Northern District
LOCATIONMORGAN & FOREMAN
ORGANIZATIONR. Everdell
PERSONPretrial Services
ORGANIZATIONPetrov
PERSON
Dominique Strauss-Kahn
PERSONDuffey
PERSONStrauss-Kahn's
PERSONWilliam S. Duffey
PERSON