Epstein Secrets

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

that she would be able to resist extradition successfully. United Kingdom. With respect to the United Kingdom, submitted herewith is a report from David Perry ("Perry Rep."), a U.K. barrister who is widely considered one of the United Kingdom's preeminent extradition practitioners. (Perry Rep. Annex B ¶ 2.

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

that she would be able to resist extradition successfully. United Kingdom. With respect to the United Kingdom, submitted herewith is a report from David Perry ("Perry Rep."), a U.K. barrister who is widely considered one of the United Kingdom's preeminent extradition practitioners. (Perry Rep. Annex B ¶ 2.

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

that she would be able to resist extradition successfully. United Kingdom. With respect to the United Kingdom, submitted herewith is a report from David Perry ("Perry Rep."), a U.K. barrister who is widely considered one of the United Kingdom's preeminent extradition practitioners. (Perry Rep. Annex B ¶ 2.

n ($49 billion) from 4.98 trillion yen a year earlier, according to the manufacturer, based in 'Thy- eta dly in central Ian. Toyota will overtake GM ac the world's No. I automaker in a few years if the current pace continues. In July. Toyota for the first time beat Ford Motor Co. in U.S. veh

he navigated New York high society. When he first attracted notice in the early 1990s. it was on account of the woman he was dating. Gh istaine Maxwell. daughter of the late British media tycoon Robert Maxwell. In a lengthy article, headlined "The Mystery of Ghislaine Max- wells Secret Love," the

largest edam residence in Manhattan, It is repotted to have closed-circuit televisJon and a heated sidewalk to melt fallen snow. Women in his life Ghislaine Maxwell, a future at elite parties and the intensely private daughter of a media tycoon, dated Epstein in the 199Os. 'I'm like 'd• Reiss; told polic

In a lengthy article, headlined "The Mystery of Ghislaine Max- wells Secret Love," the British Mail an Sun

n group in which government and private en- tities focus on disaster prepared- ness and recovery for Flonda's animal and agriculture sectors. said David Perry, a response team specialist with the state Depart- ment of Agriculture. Perry was in West Palm Beach on Friday for a hurricane- preparedness meeti

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. 20 Cr. 330 (MN) REPLY N1EMOR kNDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everde

ork, NY 10011 Phone: 212-243-1100 Attorneys for Ghislaine Maxwell EFTA00015977 --- PAGE BREAK --- TABLE

clusively on the Testimony of Three Witnesses 2 II. The Government Has Not Carried Its Burden 4 A. The Government Asks the Court to Ignore Ms. Maxwell's Substantial Ties to the United States, Including Her Spouse-4 B. Ms. Maxwell Has Thoroughly Disclosed Her Finances and Pledged All of Her and H

n 4 A. The Government Asks the Court to Ignore Ms. Maxwell's Substantial Ties to the United States, Includi

t an extradition decree would not be issued. (/d. at 3). The government offers no rebuttal to the opinion of Ms. Maxwell's U.K. extradition expert, David Perry. Nor does it dispute Mr. Perry's opinion that Ms. Maxwell would be "highly unlikely" to successfully resist extradition from the United Kingdom, tha

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Eve

Floor New York, NY 10011 Phone: Attorneys for Ghislaine Maxwell EFTA00016769 --- PAGE BREAK --- TABLE

clusively on the Testimony of Three Witnesses 2 II. The Government Has Not Carried Its Burden 4 A. The Government Asks the Court to Ignore Ms. Maxwell's Substantial Ties to the United States, Including Her Spouse 4 B. Ms. Maxwell Has Thoroughly Disclosed Her Finances and Pledged All of Her an

n 4 A. The Government Asks the Court to Ignore Ms. Maxwell's Substantial Ties to the United States, Includi

t an extradition decree would not be issued. (Id. at 3). The government offers no rebuttal to the opinion of Ms. Maxwell's U.K. extradition expert, David Perry. Nor does it dispute Mr. Perry's opinion that Ms. Maxwell would be "highly unlikely" to successfully resist extradition from the United Kingdom, tha

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Eve

ork, NY 10011 Phone: 212-243-1100 Attorneys for Ghislaine Maxwell EFTA00019291 --- PAGE BREAK --- TABLE

clusively on the Testimony of Three Witnesses 2 II. The Government Has Not Carried Its Burden 4 A. The Government Asks the Court to Ignore Ms. Maxwell's Substantial Ties to the United States, Including Her Spouse-4 B. Ms. Maxwell Has Thoroughly Disclosed Her Finances and Pledged All of Her and H

n 4 A. The Government Asks the Court to Ignore Ms. Maxwell's Substantial Ties to the United States, Includi

t an extradition decree would not be issued. (Id. at 3). The government offers no rebuttal to the opinion of Ms. Maxwell's U.K. extradition expert, David Perry. Nor does it dispute Mr. Perry's opinion that Ms. Maxwell would be "highly unlikely" to successfully resist extradition from the United Kingdom, tha

ngs in the United States prior to trial and in breach of bail; and (c) on the basis of the information currently known, it is highly unlikely' that Ghislaine Maxwell would be able successfully to resist extradition to the United States in relation to the charges in the superseding indictment dated 7 July 2020. I

ion currently known, it is highly unlikely' that Ghislaine Maxwell would be able successfully to resist ext

ail would almost certainly be refused for the duration of the extradition proceedings. (b) The majority of the bars that might be relied upon by Ms Maxwells require the extradition judge to make a finding that extradition would be oppressive. Quite apart from the other factors rendering those bars unav

oted in the Opinion13 the majority of extradition cases conclude within two years, or three months in cases where consent to extradition is given. David Perry QC 6KBW College Hill 17 December 2020 Extradition Act 2003, ss. 93(4Xb), 126(2) and 179(2). 9 Extradition Act 2003, s. 93(4Xc) and (6A). 1D Extr