4
Shared Docs
4
Same-Page
15 / 4
Mentions
ELL, Defendant. x THE GOVERNMENT'S MEMORANDUM IN SUPPORT OF DETENTION For the reasons set forth herein, the Government respectfully submits that Ghislaine Maxwell, the defendant, poses an extreme risk of flight; that she will not be able to rebut the statutory presumption that no condition or combination of co
v. GHISLAINE MAXWELL, Appellant. On Appeal from the United States District Court for the Southern District of New York, 20-CR-330 (MN) Appellant Ghislaine Maxwell's Motion for Pretrial Release David Oscar Markus MARKUS/MOSS PLLC 40 N.W. Third Street Penthouse One Miami, Florida 33128 EFTA00093045 Case 21-
3068296, Page2 of 31 No. 21-770 & 21-58 In the Mufti) Sates' Court of 5Appeats for the £ieconb (Circuit UNITED STATES OF AMERICA. Appellee, v. GHISLAINE MAXWELL, Appellant. On Appeal from the United States District Court for the Southern District of New York, 20-CR-330 (MN) Appellant Ghislaine Max
nimous that such conditions produce mental deterioration, which prevents her from effective participation in trial preparation. Worse, even if Ms. Maxwell were able to be fully alert and mentally acute, she must review over 2,500,000 prosecution pages on a gutted computer, which does not have the abil
rticipation in trial preparation. Worse, even if Ms. Maxwell were able to be fully alert and mentally acute,
hat they can effectively prepare for trial. Bernie Madoff. Harvey Weinstein. Bill Cosby. John Gotti. Marc Dreier. Dominique Strauss- Kahn. Ali Sadr. Adnan Khashoggi. Mahender Sabhnani. The list goes on and on. In each case, the court set reasonable conditions of bond and the defendants appeared, despite similar
arges against him, a „judge dismissed all criminal charges on August 29, 2019 ['Epstein had a decades-long association with the British socialite Ghislaine Maxwell, leading to her 2021 conviction on U.S. federal charges of sex trafficking and conspiracy for helping him procure girls, includin a 4-yeri old, fo
stein's close companion, told a Mend that Epstein's private island in the Virgin Islands was completely wired for video and the friend believed that Maxwell and Epstein were videotaping everyone on the island as an insurance policy.185J When police raided his Palm Beach residence in 2006, two hidden pin
in the Jeffrey , alleged in a sworn affidavit that at age 17, Epstein case (hups://www.youtube.c she had been sexually trafficked by Epstein and Ghislaine om/watch?v=yPjnercJqs1) Maxwell for their own use and for use by several others, Perversion of Justice, The Miami including Prince Andrewfi1 and r
citizens.1.3591 Personal life Previous long-term girlfriends associated with Epstein include Eva Andersson-Dubin(2°O?±-35.1 and publishing heiress Ghislaine Maxwell.(3°1 Epstein was romantically linked to Andersson-Dubin for an 11-year ri pe 04112T)61 mostly in the 198os and the two later remained friendly well af
ave it alone'", and that Epstein was "above his pay grade".[521[531 During this period, one of Epstein's clients was the Saudi Arabian businessman Adnan Khashoggi, who was the middleman in transferring American weapons from Israel to Iran, as part of the Iran-Contra affair in the 1.980s.N-Khashoggi was one of
Val of Yana C, — r-1 CD- Oat ir4.4O(bs Dea My name is I am a residence of South Australia, Australia. & — I am contacting you as a victim of Maxwell and Epstein and connected Individuals involved and connected In the case of Sexual abuse rings and grooming of girls for people in prominent positio
gainst him, a judge dismissed all criminal charges on August 29, 2O19*(17]1181 Epstein had a decades-long association with the British, socialite Ghislaine Maxwell, leading to her 2021 conviction on U.S. federal charges of sex trafficking and conspiracy for helping him procure girls, including_a 14-ye
places on his properties to allegedly record sexual activity with underage girls by prominent people for criminal purposes such as blaclunail.[843 Ghislaine Maxwell, Epstein's close companion, told a friend that Epstein's private island in the Virgin Islands was completely wired for video and the friend believed
'leave it alone', and that Epstein was "above his pay grade"5521[531 During this period, one of Epstein's clients was the Saudi Arabian businessman Adnan Khashoggi, who was the middleman in transferring American weapons from Israel to Iran, as part of the Iran—Contra affair in the 198055°1 Khashoggi was one of
a judge dismissed all criminal charges on August 29, 2019.11211-81 Epstein had a decades-long association Occupation with the British,. socialite Ghislaine Maxwell, leading to her 2021 conviction on U.S. federal charges of sex trafficking and The conspiracy for helping him procure girls, including 14-year- ol
ll meantiSncluiiii the Crime Victims (then known as , alleged in a sworn affidavit that at age 17, she had been sexually trafficked by Epstein and Ghislaine Maxwell for their own base and for use by several others, including Prince Andres41411 and retired Harvard Law professor AlanTheisliawiiimal also
ncluiiii the Crime Victims (then known as , alleged in a sworn affidavit that at age 17, she had been sexually trafficked by Epstein and Ghislaine Maxwell for their own base and for use by several others, including Prince Andres41411 and retired Harvard Law professor AlanTheisliawiiimal also claimed
eave it alone'", and that Epstein was "above his pay grade".(52K53J During this period, one of Epstein's clients was the Saudi Arabian businessman Adnan Khashoggi, who was the middleman in transferring American weapons from Israel to Iran, as part of the Iran—Contra affair in the 198os.ill' Khashoggi was one
Entities connected to both Ghislaine Maxwell and Adnan Khashoggi

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
United States
LOCATION
George W. Bush
PERSON
Bill Clinton
PERSON
Alan Dershowitz
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATION
Marc Rich
PERSON
Donald Trump
PERSONLeon Black
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
Julie K. Brown
PERSON
Virginia Giuffre
PERSON
New York
LOCATION
Les Wexner
PERSONFBI
ORGANIZATION
Alison J. Nathan
PERSONJane Doe
PERSON