Epstein Secrets

S DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, v. 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. REPLY MEMORANDUM OF GHISLAINE MAXWELL pi SUPPORT OF HER THIRD MOTION FOR RAII Bobbi C. Sternheim Law Offices of Bobbi C. Stemhcim 33 West 19th Street - 4th Floor New York NY 10011 P

th Avenue Denver CO 80203 Phone: Attorneys for Ghislaine Maxwell EFTA00031918 --- PAGE BREAK --- Preli

The issue before the Court, as it has been since Ms. Maxwell's first bail application, is whether conditions

one: Attorneys for Ghislaine Maxwell EFTA00031918 --- PAGE BREAK --- Preliminary Statement The issue before the Court, as it has been since Ms. Maxwell's first bail application, is whether conditions exist that can reasonably assure Ms. Maxwell's appearance at trial. On her third application (the "

summarily reject the proposed monitorship. William S. Duffey, Jr., a retired federal district court judge and the former United States Attorney for the Northern District of Georgia, has agreed to undertake appointment by the Court as asset monitor. Judge Duffey has extensive experience evaluating and monitoring funds held in a

nt. x 20 Cr. 330 (MN) MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S THIRD MOTION FOR RELEASE ON BAIL Bobbi C. Stern

ger HADDON, MORGAN & FOREMAN P.C. Attorneys for Ghislaine Maxwell EFTA00018709 --- PAGE BREAK --- INTRO

--- PAGE BREAK --- INTRODUCTION Ghislaine Maxwell respectfully submits this Memorandum in Support of her Third Motion for Release on Bail. As Ms. Maxwell has stated on numerous occasions and reaffirms here: she has no intention or desire to leave this country. She is an American citizen, has lived in

ort of her Third Motion for Release on Bail. As Ms. Maxwell has stated on numerous occasions and reaffirms he

3. Selected Asset Monitor The Honorable William S. Duffey, Jr., a retired federal District Court judge and the former United States Attorney for the Northern District of Georgia, has agreed to undertake the position of asset monitor. (Judge Duffey's bio is attached as Exhibit A.) Judge Duffey has extensive experience evalua

This is not to say there aren't many victims who are eager to see Epstein face new charges in South Florida, wrote Byung J. Pak, U.S. Attorney for the Northern District of Georgia, and Jill E. Steinberg and Nathan P. Kitchens, special attorneys for the Southern District of Florida. But they conclude that reopening their cases

rported connections to Donald Trump, Bill Clinton and Prince Andrew, and moved in elite circles, including for several years in a relationship with Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell. Epstein and the Miami US attorney's office, headed at the time by Alexander Acosta, broke

r several years in a relationship with Ghislaine Maxwell, daughter of the late British media tycoon Robert

cluding for several years in a relationship with Ghislaine Maxwell, daughter of the late British media tycoo