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

n that never shifts, has not made a showing as required, that our client is a risk of flight. When you consider the risk, as Judge Raggi put it, in Sabhnani, the actual risk of flight, not fantasy and not speculation, when you consider that the only factors they really point to are ones that the cases

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

n that never shifts, has not made a showing as required, that our client is a risk of flight. When you consider the risk, as Judge Raggi put it, in Sabhnani, the actual risk of flight, not fantasy and not speculation, when you consider that the only factors they really point to are ones that the cases

r-00330-AJN Document 18 Filed 07/10/20 Page 1 of 26 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 OPPOSITION TO THE GOVERNMENT'S MOTION FOR DETENTION Mark S. Cohen Christian

olorado 80203 Phone: 303-831-7364 Attorneys for Ghislaine Maxwell EFTA00018515 --- PAGE BREAK --- Case

f 26 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 ARGUMENT 5 I. The Conditions Created by the COVID-19 Pandemic Mandate the Release of Ms. Maxwell. 5 II. The Government Has Not Carried Its Burden Under 18 U.S.C. § 3142. 9 A. Applicable Law 9 B. Ms. Maxwell Has Rebutted the Presumption T

by the COVID-19 Pandemic Mandate the Release of Ms. Maxwell. 5 II. The Government Has Not Carried Its Burd

WL 3536277 (2d Cir. June 30, 2020) 10 United States v. Moscaritolo, No. 10 Cr. 4 (JL), 2010 WL 309679 (D.N.H. Jan. 26, 2010) 18 United States v. Sabhnani, 493 F.3d 63 (2d Cir. 2007) 9, 10, 16, 18 United States v. Salerno, 481 U.S. 739 (1987) 9 United States v. Stephens, 15-CR-95 (AJN), 2020 WL 1

Supp. 3d 283, 292 (E.D.N.Y. 2014) (Bianco, J.) (collecting cases). The Second Circuit has never directly addressed this issue. See United States v. Sabhnani, 493 F.3d 63, 78 n.18 (2d Cir. 2007) ("The government has not argued and, therefore, we have no occasion to consider whether it would be `contrary

orro Ranch Corporation, New York Strategy Group, Ghislaine Corporation, J Epstein and Company and the Finan