Epstein Secrets

ority of the bars that might be relied upon by Ms Maxwells require the extradition judge to make a finding

ts, a review that formed the basis of changes to the 2003 Extradition Act. (Id. Annex B ¶ 3.1). In Mr. Perry's opinion, it is "highly unlikely that Ghislaine Maxwell would be able successfully to resist extradition to the United States" in connection with this case. (Perry Rep. 12(e)). After concluding that none

ide any answer on this issue. 2 The DOJ Memorandum and the Peterson Case In support of its argument that the French government would not extradite Ms Ghislaine Maxwell to the USA, the government relies on the case of Mr Hans Peterson, a dual French American citizen whose extradition to the US was denied by

seding indictment dated 7 July 2020. In addition to those conclusions, the following three points may be made. 3. First, as noted in the Opinion2, Ms Maxwell's waiver of extradition would be admissible in any extradition proceedings in England and Wales. While such a document cannot compel a requested pers

r, CO 80203 Phone: Bobbi C. Sternheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: Attorneys for Ghislaine Maxwell II EFTA00093319 cailase:20-agloDacument ntlinfiAtIllf0891, 806E128B2Blage34figrl 3tI 4 Exhibit A EFTA00093320 Ckast.20-U-0003.00dblit DOditrehlei

l's mouth, which heightens her risk of contracting the deadly virus, which has now surged to 113 positive cases in the MDC. Further, Deputy Captain B. Houtz recently issued a memo stating that "[i]t has not been determined whether legal calls and legal visits will continue." As the Court is well aware,

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

l's mouth, which heightens her risk of contracting the deadly virus, which has now surged to 113 positive cases in the MDC. Further, Deputy Captain B. Houtz recently issued a memo stating that "(ijt has not been determined whether legal calls and legal visits will continue." As the Court is well aware,

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

l's mouth, which heightens her risk of contracting the deadly virus, which has now surged to 113 positive cases in the MDC. Further, Deputy Captain B. Houtz recently issued a memo stating that "[i]t has not been determined whether legal calls and legal visits will continue." As the Court is well aware,

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

l's mouth, which heightens her risk of contracting the deadly virus, which has now surged to 113 positive cases in the MDC. Further, Deputy Captain B. Houtz recently issued a memo stating that "[i]t has not been determined whether legal calls and legal visits will continue." As the Court is well aware,