Epstein Secrets

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

sal criminality" and alleged to be a "high flight risk," granted release subject to conditions); United States v. Madoff, 586 F. Supp. 2d 240, 243 (S.D.N.Y. 2009) (Bernie Madoff, charged with "largest Ponzi scheme ever and alleged to be a "serious risk of flight," granted release subject to conditions). not

ited States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in opposition to the defendant's letter of August 17, 2020 (t

, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Govern

New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: Th

affect law enforcement interests.") (citing United States v. Amodeo, 71 F.3d 1044, 1050)); see also United States v. Park, 619 F. Supp. 2d 89, 94 (S.D.N.Y. 2009) (holding that the need to "maintain the secrecy of the Government's investigation" outweighed the public's right of access to certain sentencing d

:20-cr-00330-AJN Document 168 Filed 03/18/21 Page 1 of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC //: DATE FILED: 3/18/21 20-CR-330 (MN) ORDER ALISON J. NATHAN, District Judge: On

TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTR

e investigation, as the individuals and entities under investigation would be put on notice." United States v. Madoff, 626 F. Supp. 2d 420, 427-28 (S.D.N.Y. 2009). And the Government's interest in protecting an ongoing investigation from the "danger of impairing law enforcement" may be a countervailing facto

Exhibit 11 entirely under seal. While portions of that transcript have been redacted, other portions are part of the public record. See Giuffre v. Maxwell, Case No. 15-cv-7433, Dkt. No. 1212-1. In light of this, the Court sees no basis to file the transcript entirely under seal rather than by redacting