Epstein Secrets

t's response to, and that is the contention that Ms. Maxwell, through counsel, kept in touch with the governm

URT: there is one assertion in the defense papers that I don't think I have seen the government's response to, and that is the contention that Ms. Maxwell, through counsel, kept in touch with the government since the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00093148 Case 21-770, Docume

ay in order to protect her privacy. The following are the words of Jane Doe which I will read from her written statement. Jane Doe wrote: "I knew Ghislaine Maxwell for over ten years. It was her calculating and sadistic manipulation that anesthetized me, in order to deliver me, with full knowledge of the heino

n order to deliver me, with full knowledge of the heinous and dehumanizing abuse that awaited me, straight to the hands of Jeffrey Epstein. Without Ghislaine, Jeffrey could not have done what he did. She was in charge. She egged him on and encouraged him. She told me of others she recruited and she thou

man Loera, and Mr. Raniere combined. ALL U.S. MEDIA COVERAGE COMPARISON (90 DAYS OF ARREST) 7.000 6.000 6000 6.000 6 too° 3 2.000 1000 0 GM IS LAIN E MAXWELL •la ray Weinst•in Erri"nrEME‘rantrrrIMMTI. . Bill Catty JC•ClUll% Guzman Leera Keith Raffle's 21 EFTA00093242 C6set1211-Z7

o had introduced herself as Janet Marshall, who had toured the house and participated in these conversations about the purchase, was the defendant, Ghislaine Maxwell. That series of facts, which I just learned about this morning, your Honor, are concerning for two reasons. First, additionally, it appears that t

tions. Doesn't mean the government has carried its burden of showing there is no combination of conditions. In the Khashoggi case, written by Judge Keenan in 1989, this was a person of extraordinary wealth, way more than anything the government alleges that our client has, he was, according to the go

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 Jeffrey S. Pagliuca Laura A. Menninger HADDO

ESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Ghislaine Maxwell EFTA00065716 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 ARGUMENT 7 1. 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

ra, and Mr. Raniere combined. ALL U.S. MEDIA COVERAGE COMPARISON (90 DAYS OF ARREST) 7.000 6.000 5.000 V t y 4,000 IJ moo 2.000 1.000 0 GIIISLAINE MAXWELL Hanmy Weirismo, rin*Trifirrnr,77.S 166171MITTETaUll Bill Cathy Jo Quln Gungn Lon Kolth Ramiro 21 EFTA00065742 2. Ms. Maxwell's Counsel Was i

gnized as an indication of the defendant's intent not to flee. See, e.g., United States v. Khashoggi, 717 F. Supp. 1048, 1052 (S.D.N.Y. 1989) (Judge Keenan found defendant's extradition appeal waiver "manifests an intention to remain here and face the charges against him"). In response to the governme

T SOUTHERN DISTRICT OF NEW YORK x 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. Before: New York, N.Y. 20 Cr. 330 (AJN) x Teleconference Arraignment Bail Hearing July 14, 2020 3:05 p.m. HON. ALISON

S, P.C. (212) 805-0300 EFTA00066216 k7e2MaxC kjc THE COURT: Good afternoon, everyone. This is Judge Nathan presiding. This is United States v. Ghislaine Maxwell, 20 Cr. 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 330. I will take appearances from counsel, beginning with

I will take appearances from counsel, beginning with counsel for the defendant. : Good afternoon, your Honor. Mark Cohen, Cohen & Gresser, for Ms. Maxwell. Also appearing with me today is my partner Chris Everdell of Cohen & Gresser and Jeff Pagliuca and Laura Menninger of the Haddon Morgan firm. Good

on, your Honor. Mark Cohen, Cohen & Gresser, for Ms. Maxwell. Also appearing with me today is my partner Chri

o had introduced herself as Janet Marshall, who had toured the house and participated in these conversations about the purchase, was the defendant, Ghislaine Maxwell. That series of facts, which I just learned about this morning, your Honor, are concerning for two reasons. First, additionally, it appears that t

tions. Doesn't mean the government has carried its burden of showing there is no combination of conditions. In the Khashoggi case, written by Judge Keenan in 1989, this was a person of extraordinary wealth, way more than anything the government alleges that our client has, he was, according to the go

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 Jeffrey S. Pagliuca Laura A. Menninger HADDO

ESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Ghislaine Maxwell EFTA00154512 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 ARGUMENT 7 1. 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

ra, and Mr. Raniere combined. ALL U.S. MEDIA COVERAGE COMPARISON (90 DAYS OF ARREST) 7.000 6.000 5.000 V t y 4,000 IJ moo 2.000 1.000 0 GIIISLAINE MAXWELL Hanmy Weirismo, rin*Trifirrnr,77.S 166171MITTETaUll Bill Cathy Jo Quln Gungn Lon Kolth Ramiro 21 EFTA00154538 2. Ms. Maxwell's Counsel Was i

gnized as an indication of the defendant's intent not to flee. See, e.g., United States v. Khashoggi, 717 F. Supp. 1048, 1052 (S.D.N.Y. 1989) (Judge Keenan found defendant's extradition appeal waiver "manifests an intention to remain here and face the charges against him"). In response to the governme

4 Dividend and interest income 98.71 741.17 Change in market value -87.52 119.05 Closing account value $57,634.45 $57,634.45 Account name: GHISLAINE MA (WELL IRA Friendly account name:Indiv IRA Account type: Individual Retirement ACCOunt Account number. Dividend and interest income earned For o

ategic Advisor June 2017 Account namC GHIELANE MAXWELL IRA Friendly account name: Incliv: IRA Account type: Individual Retirement Account HIS AN MAXWELL RA Account number. Your linandal Advisor. SCOTT STACKMAN/LYLE CASRIEL Phone: Value of your account Questions about your statement? Call your F

ncome 5360.33 Change in market vat* $15493 Value of year arcane Dec 2014 Dec 2015 Dec 2016 may 2017 tun 2017 imam 30, 2017 07507.24 SONY GM 00028824 Member SIPC 0010000306584587 Nn7000306478 00004 0617 030575004 110110 Page 1 of 8 CONFIDENTIAL EFTA_00137444 EFTA01278351 *UBS UBS

itional 0.00 000% F Commodities 0.00 000% G Other 000% Total assets Value of your account 157,507.24 $57,507.24 100.00% Account name: GHISLAINE MAXWELL IRA Friendly account nome:Indiv IRA Account type: Individual Retirement Account Account number: Your current asset allocation A D Eye

157,507.24 $57,507.24 100.00% Account name: GHISLAINE MAXWELL IRA Friendly account nome:Indiv IRA Account typ

to up to $1.9 million n the aggregate tor anti accounts Fold n spanking capacity AM copy of the poky woolig is ankh won request. Neither tie SIPC Keenan nor the swphroental praetor, apply to: • Certain franca assets controlled by (and next n your account value) but held awayfrom UBSFinancel Servic

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

gnized as an indication of the defendant's intent not to flee. See, e.g., United States v. Khashoggi, 717 F. Supp. 1048, 1052 (S.D.N.Y. 1989) (Judge Keenan found defendant's extradition appeal waiver "manifests an intention to remain here and face the charges against him"). In response to the governme

ority of the bars that might be relied upon by Ms Maxwells require the extradition judge to make a finding

ts, a review that formed the basis of changes to the 2003 Extradition Act. (Id. Annex B ¶ 3.1). In Mr. Perry's opinion, it is "highly unlikely that Ghislaine Maxwell would be able successfully to resist extradition to the United States" in connection with this case. (Perry Rep. 12(e)). After concluding that none

ide any answer on this issue. 2 The DOJ Memorandum and the Peterson Case In support of its argument that the French government would not extradite Ms Ghislaine Maxwell to the USA, the government relies on the case of Mr Hans Peterson, a dual French American citizen whose extradition to the US was denied by

seding indictment dated 7 July 2020. In addition to those conclusions, the following three points may be made. 3. First, as noted in the Opinion2, Ms Maxwell's waiver of extradition would be admissible in any extradition proceedings in England and Wales. While such a document cannot compel a requested pers

r, CO 80203 Phone: Bobbi C. Sternheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: Attorneys for Ghislaine Maxwell II EFTA00093319 cailase:20-agloDacument ntlinfiAtIllf0891, 806E128B2Blage34figrl 3tI 4 Exhibit A EFTA00093320 Ckast.20-U-0003.00dblit DOditrehlei

gnized as an indication of the defendant's intent not to flee. See, e.g., United States v. Khashoggi, 717 F. Supp. 1048, 1052 (S.D.N.Y. 1989) (Judge Keenan found defendant's extradition appeal waiver "manifests an intention to remain here and face the charges against him"). In response to the governme

0617285 Jack A. Goldberger, Esq. Atterbury Golderger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach FL 33401-5012 Doe v. Ghislaine Maxwell 09/24/2009 MSC Cohen & Grasser LLP 100 Park Avenue New York, New York 10017 Telephone Fax Tax #16-1645666 Fees telepilorie conference with

ees telepilorie conference with G. Maxwell; donferenceS,with B. Jaffe; e-Mails re case. 10/05/2009 BDJ Conference with M. Cohen; conference with G. Maxwell; review documents re: same. MSC Conference with B. Jaffe; telephone conferences with client; telephone conferences re case. MSC G. Maxwell — tel

West Palm Beach FL 33401-5012 Doe v. Ghislaine Maxwell 09/24/2009 MSC Cohen & Grasser LLP 100 Park A

Suite 1400 West Palm Beach FL 33401-5012 Doe v. Ghislaine Maxwell 09/24/2009 MSC Cohen & Grasser LLP 10

Telephone conference with J. Goldberger and B. Jaffe; telephone conference with client; review materials. AS Discussion with Part I clerk; review Keenan and Stein discovery opinions; JA Printed and assembled cases for attorney review. BDJ Telephone conference with J. Goldberger, M. Cohen; Teleph

This document was added on 7-5-2o2o. Ghislaine Maxwell and her MA-NH ties... https://docs.google.com/do

friends in the law enforcement section of Ebay to delete, alter , or have them reissued to a random person not tied to them! EFTA00083281 rofile ghislaine55 (276 ) Positive Feedback (last 12 months): 100% 0 Member since: Dec-01-03 in United States I believe Capuano who pimped the child out has since r

ht I would, and my new document titled Epstein, Ghislaine, and O'Connell ties is below. Harboring a fugitive? This document was added on 7-5-2o2o. Ghislaine Maxwell and her MA-NH ties... https://docs.google.com/document/d/1DILdQv9FMJFM -qe-SyJsvr4Yp8006sDgliOZ3 zDwhc/edit?usp=sharing If you send this document

ape and cocaine trafficking. O'Connell is good friends with Norfolk DA Mike Morrissey, Rep Bruce Ayers, the Kanes who own BNEG nightclubs, Senators Keenan, Keating, and Senator Brian Joyce, FX Messina, and several politicians including Delahunt. He's also described as one of the most powerful Massachu

ued Reporting: AG Bondi Has a New Probe Into the Handling of 2016 Russian Meddling • Continued Reporting: Judge Will Not Unseal Grand Jury Papers of Maxwell, Epstein's Companion • Former Indianapolis Police Officer Involved in Undercover Cocaine Transaction • South Dakota Highway Patrol Seized Over Two

s (08/11, Meko) reported that a Manhattan federal judge denied the government's request to unseal grand jury transcripts from the investigation into Ghislaine Maxwell, Jeffrey Epstein's companion. According to the article, the judge stated that unsealing the transcripts would erode confidence in people called to t

rand jury transcripts from the investigation into Ghislaine Maxwell, Jeffrey Epstein's companion. According

Back to Top CRIMINAL INVESTIGATIONS Continued Reporting: Atlanta CDC, Emory University Shooting The New York Times (08/11, McFadden, Mandavilli, Keenan) reported that on August 8, 2025, a shooting at the CDC headquarters in Atlanta left DeKalb County Police Officer David Rose, 33, and the suspected