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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. E
URT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF 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. Pagliuc
DDON, MORGAN & FOREMAN P.C. Denver, CO 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim New York, NY 10011 Phone: Attorneys for Ghislaine Maxwell EFTA00094289 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 ARGUMENT 7 I. Reconsideration of the Court's Bail Decision is Appropriate Under
is Appropriate Under 18 U.S.C. § 3142(O 7 II. Ms. Maxwell Should Be Granted Bail Under the Proposed Strict
e to an August 14, 2019 news report that Ms. Maxwell might be living in Massachusetts, one person wrote: SHE'S HERE in #Massachusetts ?! The bitch #GhislaineMaxwell who #SexTrafficked young girls for #Epstein ?!?! Why the hell isn't she being brought in for questioning @ManchesterMAPD ?! WE DO NOT WANT HER HER
0 in cash. o A $25,000 bond signed by Simon Lyons, a close family friend, and fully secured by $25,000 in cash. The cash security is money that Mr. Lyons planned to set aside for his own daughter's future, but he is prepared to pledge it for Ms. Maxwell. o A $2,000 bond signed by Jeff Paul Roth, a c
lenge should be dismissed." Lord Justice Bean and Mr Justice Lewis "are expected to deliver a ruling in the near future." CRIMINAL INVESTIGATIONS Ghislaine Maxwell Reportedly Refuses To Reveal Name Of Spouse To FBI. The London (UK) Evening Standard (7/15, Somerville, 856K) reports, "Ghislaine Maxwell is secret
to charges she had trafficked at least three underage girls for billionaire paedophile Jeffrey Epstein." Assistant US Attorney Alison Moe "revealed Maxwell had a spouse while questioning who would co-sign her bond at a bail hearing in New York. She told the courthouse late on Tuesday: 'In addition to fa
dges' Inquest Ruling. CRIMINAL INVESTIGATIONS • Ghislaine Maxwell Reportedly Refuses To Reveal Name Of Spou
re imposed by U.S. Eastern District Judge Jeffrey L. Schmehl, U.S. Attorney William M. McSwain said Wednesday. The sentencing came nine months after Lyons, 59, pleaded guilty to charges that he provided false financial documents to secure tens of millions of dollar in financing from Fulton Bank betwee
ree years. Epstein has paid to erform Swedish Massages (Deep Tissue) on him and other guests. explained that approximately three year ago she met Ghislaine Maxwell and Jeffrey Epstein through a mutual friend. Epstein and Maxwell were looking for a massage therapist. stated since that time, she is notified wh
et Epstein three years ago when Ghaline Maxwell approached her while she was attending Palm Beach Atlantic College to work around Epstein's house. Maxwell had told her that they needed some irls to work at the house to answer phones and run errands. accepted the job and be an working at Epstein's hou
lained that approximately three year ago she met Ghislaine Maxwell and Jeffrey Epstein through a mutual fri
33304 Re: THE PO INGRAPli EXAMINATION Or` JEFFREY EDWARD EPSTEI N, SIATTERY ASSOCIATES, INC. FILE #06-0851(5), EXAMINED ON MAY 2, 2006 Dear Mr. Lyons: As you advised, your above named client is apparently suspected of inappropriate sexual activity with a juvenile female, s Her real name, which i
ssipative structure approach, presumably there is a negentropy flow associated with 'maintaining' the dissipative structure in its low entropy form; Maxwell's demon is continually at work narrowing the spread of the distribution. However if this negentropy flow is smaller than the entropy flow through t
distribution [Levy & Solomon 1996]. In contrast the Maxwell-Boltzmann distribution of a normal thermodynamic
ll reviewed in papers by Stoll, Madhavan and Biais et al, Stoll is a particularly good introduction [Stoll 2003, Madhavan 2000, Biais et al 2005]. Lyons discusses this with great clarity in 'The Microstructure Approach to Exchange Rates' [Lyons 2001]. In sections 6.3 to 6.5 Lyons captures the differe
cember 18, 2017 4:56 PM To: Hughes, Rob Marker, Maxwell D. (CID) (FBI) < John J. (CID) (FB Cohen, Bradl
+0000 Importance: Normal Amanda, See below, any bullets you can give me on VCAC in Baltimore besides that they can't select good SSA's? JB From: Lyons, Kevin P. (CID) (FBI) Sent: Monday, December 18, 2017 4:56 PM To: Hughes, Rob Marker, Maxwell D. (CID) (FBI) < John J. (CID) (FB Cohen, Bradley
last year. Eli Rosenberg reports: "A jury found Maxwell Hare, 27, of Harrisburg, Pa., and John Kinsman,
enier, activist anti-Semite and white supremacist filed again for a Chicago-area House seat. From the Chicago Sun-Times: "Arthur Jones, of suburban Lyons, won the GOP nomination in 2018 because he was the only Republican on the 3rd District primary ballot. In the general election, he was easily beate
se we don’t trust government. In response, Judge Maxwell Cohen said that anyone who holds such views “ough
pparent reason. They sat immobilized by horror as Randy Greenawalt drove them away in the orange Mazda. Soon thereafter the Arizona police found the Lyons family. Mother, baby and John were in or near the white Lincoln, shot to death. The niece was missing, raising the fear that she had been kidnapped b
ew the SFO are not under a common law duty of disclosure, although some disclosure may be necessary in some cases.' 1 R v Serious Fraud Office ex p Maxwell (Kevin)The Times. 9 October 1992. A.7.312 In Marlurood Commercial Inc v Konen! the Court of Appeal dealt with an application made by a party to civ
Page: EFTA00022257 →prevent end use in any subsequent prosecution. I Para 5 of Sch 1 to CICA 2003. 2 R v Director of the Serious And Office ex p Smith 11993) AC I. 3 Lyons 120031 1 AC 976: Brown v Stott (Procurator Fund, Dunfermline) 120031 2 AC 68 I; R v Hertfordshire County Council ex p (Awn Environmental Industries
Page: EFTA00022263 →Entities connected to both Ghislaine Maxwell and Lyons

Jeffrey Epstein
PERSON
Prince Andrew
PERSONSouthern District
LOCATION
United States
LOCATION
George W. Bush
PERSON
Bill Clinton
PERSON
Newark
LOCATION
Alan Dershowitz
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATION
Marc Rich
PERSON
FedEx
ORGANIZATION
Donald Trump
PERSONLeon Black
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
Julie K. Brown
PERSON
Eric Trump
PERSONDarren Indyke
PERSON
Virginia Giuffre
PERSON