Epstein Secrets

rship with Jeffrey Epstein, a serial sexual predator, exploited and abused young girls for years. As a result of her disturbing and callous conduct, Maxwell now faces the very real prospect of serving many years in prison. The strength of the Government's evidence and the substantial prison term the def

-x UNITED STATES OF AMERICA 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S MEMORANDUM IN

-x UNITED STATES OF AMERICA 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S MEMORA

LL, Defendant. x THE GOVERNMENT'S MEMORANDUM IN SUPPORT OF DETENTION For the reasons set forth herein, the Government respectfully submits that Ghislaine Maxwell, the defendant, poses an extreme risk of flight; that she will not be able to rebut the statutory presumption that no condition or combination of co

ential sentence, the more probable the flight risk is, especially considering the strong case of the government . . . .") (quoting United States v. Alindato—Perez, 627 F. Supp. 2d 58, 66 (D.P.R. 2009)). Here, the defendant is facing a statutory maximum of decades in prison. This fact alone would provide

LL, Defendant. x THE GOVERNMENT'S MEMORANDUM IN SUPPORT OF DETENTION For the reasons set forth herein, the Government respectfully submits that Ghislaine Maxwell, the defendant, poses an extreme risk of flight; that she will not be able to rebut the statutory presumption that no condition or combination of co

rship with Jeffrey Epstein, a serial sexual predator, exploited and abused young girls for years. As a result of her disturbing and callous conduct, Maxwell now faces the very real prospect of serving many years in prison. The strength of the Government's evidence and the substantial prison term the def

-x UNITED STATES OF AMERICA 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. ______________________ ------x TH

-x UNITED STATES OF AMERICA 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. ______________________ ---

ential sentence, the more probable the flight risk is, especially considering the strong case of the government . . . .") (quoting United States v. Alindato—Perez, 627 F. Supp. 2d 58, 66 (D.P.R. 2009)). Here, the defendant is facing a statutory maximum of decades in prison. This fact alone would provide

rship with Jeffrey Epstein, a serial sexual predator, exploited and abused young girls for years. As a result of her disturbing and callous conduct, Maxwell now faces the very real prospect of serving many years in prison. The strength of the Government's evidence and the substantial prison term the def

-x UNITED STATES OF AMERICA 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S MEMORANDUM IN

-x UNITED STATES OF AMERICA 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S MEMORAN

LL, Defendant. x THE GOVERNMENT'S MEMORANDUM IN SUPPORT OF DETENTION For the reasons set forth herein, the Government respectfully submits that Ghislaine Maxwell, the defendant, poses an extreme risk of flight; that she will not be able to rebut the statutory presumption that no condition or combination of co

potential sentence, the more probable the flight risk is, especially considering the strong case of the government . .") (quoting United States v. Alindato—Perez, 627 F. Supp. 2d 58, 66 (D.P.R. 2009)). Here, the defendant is facing a statutory maximum of decades in prison. This fact alone would provide

LL, Defendant. x THE GOVERNMENT'S MEMORANDUM IN SUPPORT OF DETENTION For the reasons set forth herein, the Government respectfully submits that Ghislaine Maxwell, the defendant, poses an extreme risk of flight; that she will not be able to rebut the statutory presumption that no condition or combination of co

rship with Jeffrey Epstein, a serial sexual predator, exploited and abused young girls for years. As a result of her disturbing and callous conduct, Maxwell now faces the very real prospect of serving many years in prison. The strength of the Government's evidence and the substantial prison term the def

-x UNITED STATES OF AMERICA 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. -x THE GOVERNMENT'S MEMORANDUM IN

-x UNITED STATES OF AMERICA 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. -x THE GOVERNMENT'S MEMORA

ential sentence, the more probable the flight risk is, especially considering the strong case of the government . . . .") (quoting United States v. Alindato—Perez, 627 F. Supp. 2d 58, 66 (D.P.R. 2009)). Here, the defendant is facing a statutory maximum of decades in prison. This fact alone would provide

rship with Jeffrey Epstein, a serial sexual predator, exploited and abused young girls for years. As a result of her disturbing and callous conduct, Maxwell now faces the very real prospect of serving many years in prison. The strength of the Government's evidence and the substantial prison term the def

-x UNITED STATES OF AMERICA 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S MEMORANDUM IN

-x UNITED STATES OF AMERICA 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S MEMORA

LL, Defendant. x THE GOVERNMENT'S MEMORANDUM IN SUPPORT OF DETENTION For the reasons set forth herein, the Government respectfully submits that Ghislaine Maxwell, the defendant, poses an extreme risk of flight; that she will not be able to rebut the statutory presumption that no condition or combination of co

ential sentence, the more probable the flight risk is, especially considering the strong case of the government . . . .") (quoting United States v. Alindato—Perez, 627 F. Supp. 2d 58, 66 (D.P.R. 2009)). Here, the defendant is facing a statutory maximum of decades in prison. This fact alone would provide

x UNITED STATES OF AMERICA 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. ------------------------- --------

--------- ----- x THE GOVERNMENT'S MEMORANDUM IN SUPPORT OF DETENTION For the reasons set forth herein, the Government respectfully submits that Ghislaine Maxwell, the defendant, poses an extreme risk of flight; that she will not be able to rebut the statutory presumption that no condition or combinat

----- x THE GOVERNMENT'S MEMORANDUM IN SUPPORT OF DETENTION For the reasons set forth herein, the Government respectfully submits that Ghislaine Maxwell, the defendant, poses an extreme risk of flight; that she will not be able to rebut the statutory presumption that no condition or combination of co

ential sentence, the more probable the flight risk is, especially considering the strong case of the government . . . .") (quoting United States v. Alindato—Perez, 627 F. Supp. 2d 58, 66 (D.P.R. 2009)). Here, the defendant is facing a statutory maximum of decades in prison. This fact alone would provide

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

ngly, the asserted potential for a long sentence does not meet the government's burden of persuasion.14 14 The government relies on United States v. Alindato-Perez, 627 F. Supp. 2d 58, 66 (D.P.R. 2009), cited approvingly by United States v. Moscaritolo, No. 10 Cr. 4 (JL), 2010 WL 309679, at •2 (D.N.H. Jan