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

ning levels of media interest meant There are many examples of violence whose seeds were born in conspiracy theories, and the experiences of QAnon, Pizzagate, and the recent Judge Salas attack are terrifying.... It is hard to communicate in words the feelin of bein stalk siedu nand ha b constant 24/7

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

ning levels of media interest meant There are many examples of violence whose seeds were born in conspiracy theories, and the experiences of QAnon, Pizzagate, and the recent Judge Salas attack are terrifying.... It is hard to communicate in words the feelin of being stalked, s ied u n and Ira b constan

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

quiet existence became unbearable. There are many examples of violence whose seeds were born in conspiracy theories, and the experiences of QAnon, Pizzagate, and the recent Judge Salas attack are terrifying.... It is hard to communicate in words the feeling of being stalked, spied upon and trapped by c

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

ning levels of media interest meant There are many examples of violence whose seeds were born in conspiracy theories, and the experiences of QAnon, Pizzagate, and the recent Judge Salas attack are terrifying.... It is hard to communicate in words the feelin of being stalked, s ied u n and Ira b constan

Exhibit A EFTA00065815 CONFIDENTIAIJPRIVILEGED/SEALED November 19, 2020 Dear Judge Nathan, I respectfully submit this letter in 5111)1)011 of Ghislaine Maxwell's bail application. History 1. 2. 3. 4. The person described in the criminal charges is not the person we know. I have never witnessed anything c

1. 2. 3. 4. The person described in the criminal charges is not the person we know. I have never witnessed anything close to inappropriate with Ghislaine; quite to the contrary, the Ghislaine I know is a wonderful and loving rson. Privacy 5. Until the explosion of media interest that followed the a

lly submit this letter in 5111)1)011 of Ghislaine Maxwell's bail application. History 1. 2. 3. 4. The

ning levels of media interest meant There are many examples of violence whose seeds were born in conspiracy theories, and the experiences of QAnon, Pizzagate, and the recent Judge Salas attack are terrifying. ere are many other gross an sgustmg posts e s on t e we t a simple searc will bring up. I h

00065658 CONFIDENTIAUPRIVILEGED/SEALED November 19, 2020 Dr. Scott Bor erson Dear Judge Nathan, I respectfully submit this letter in support of Ghislaine Maxwell's bail application. History 1. I met Ghislaine Maxwell in 2013 at the introduction of a mutual friend. 2. Ghislaine and I developed a friendship thr

s letter in support of Ghislaine Maxwell's bail application. History 1. I met Ghislaine Maxwell in 2013 at the introduction of a mutual friend. 2. Ghislaine and I developed a friendship through a shared passion for ocean conservation which over time grew into a close personal relationship. As the years p

tfully submit this letter in support of Ghislaine Maxwell's bail application. History 1. I met Ghislaine

s quiet existence became unbearable. There are many examples of violence whose seeds were born in conspiracy theories, and the experiences of QAnon, Pizzagate, and the recent Judge Salas attack are terrifying. Some of the outlandish conspiracy allegations on the intemet have insinuated that I am somehow

00154393 CONFIDENTIAUPRIVILEGED/SEALED November 19, 2020 Dr. Scott Borgerson Dear Judge Nathan, I respectfully submit this letter in support of Ghislaine Maxwell's bail application. History 1. I met Ghislaine Maxwell in 2013 at the introduction of a mutual friend. 2. Ghislaine and I developed a friendship thr

s letter in support of Ghislaine Maxwell's bail application. History 1. I met Ghislaine Maxwell in 2013 at the introduction of a mutual friend. 2. Ghislaine and I developed a friendship through a shared passion for ocean conservation which over time grew into a close personal relationship. As the years p

tfully submit this letter in support of Ghislaine Maxwell's bail application. History 1. I met Ghislaine

s quiet existence became unbearable. There are many examples of violence whose seeds were born in conspiracy theories, and the experiences of QAnon, Pizzagate, and the recent Judge Salas attack are terrifying. Some of the outlandish conspiracy allegations on the intemet have insinuated that I am somehow

Exhibit A EFTA00154502 CONFIDENTIAIJPRIVILEGED/SEALED November 19, 2020 Dear Judge Nathan, I respectfully submit this letter in 5111)1)011 of Ghislaine Maxwell's bail application. History 1. 2. 3. 4. The person described in the criminal charges is not the person we know. I have never witnessed anything c

1. 2. 3. 4. The person described in the criminal charges is not the person we know. I have never witnessed anything close to inappropriate with Ghislaine; quite to the contrary, the Ghislaine I know is a wonderful and loving rson. Privacy 5. Until the explosion of media interest that followed the a

lly submit this letter in 5111)1)011 of Ghislaine Maxwell's bail application. History 1. 2. 3. 4. The

ning levels of media interest meant There are many examples of violence whose seeds were born in conspiracy theories, and the experiences of QAnon, Pizzagate, and the recent Judge Salas attack are terrifying. ere are many other gross an sgustmg posts e s on t e we t a simple searc will bring up. I h

1. 2. 3. 4. The person described in the criminal charges is not the person we know. I have never witnessed anything close to inappropriate with Ghislaine; quite to the contrary, the Ghislaine I know is a wonderful and loving rson. Privacy 5. Until the explosion of media interest that followed the a

I respectfully submit this letter in support of Ghislaine Maxwell's bail application. History 1. 2. 3. 4. The

tfully submit this letter in support of Ghislaine Maxwell's bail application. History 1. 2. 3. 4. The

ning levels of media interest meant There are many examples of violence whose seeds were born in conspiracy theories, and the experiences of QAnon, Pizzagate, and the recent Judge Salas attack are terrifying. are many other gross an sgustmg posts e on e we t a simp e searc will bring up. I have also