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ISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, v. 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER THIRD MOTION FOR RAIL Bobbi C. Sternheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York NY
URT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, v. 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER THIRD MOTION FOR RAIL Bobbi C. Sternheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York NY 10011 P
pursuant to a request from Olivier Laude, a partner at the French firm Laude Esquier Champey acting on behalf of Cohen & Gresser LLP as counsel for Ms Ghislaine Maxwell. The request was made in the context of ongoing bail proceedings involving Ms Maxwell in the United States of America (hereafter "USA"), where Ms M
The issue before the Court, as it has been since Ms. Maxwell's first bail application, is whether conditions
ncankcom - PALAIS C 1852 EFTA00104548 WILLIAM JULIE AVOCAT A LA COUR - ATTORNEY AT LAW extradition and other removals", ECU-IR 12 April 2012, Babar Ahmad and Others v. the United Kingdom, no. 24027/07, §168). 23. France has no difficulty with deporting individuals who have lost French nationality by
ant presented to the Court at the initial bail hearing was undisputedly incomplete, and as the Court noted, the Court lacked "a clear picture of Ms. Maxwell's finances and the resources available to her." Tr. at 86 87. The Defendant has now presented to the Court what is perhaps a more thorough report o
pursuant to a request from Olivier Laude, a partner at the French firm Laude Esquier Champey acting on behalf of Cohen & Gresser LLP as counsel for Ms Ghislaine Maxwell. The request was made in the context of ongoing bail proceedings involving Ms Maxwell in the United States of America (hereafter "USA"), where Ms M
207a0063390eNt Thaatiallat 1 [email protected] UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S THIRD MOTION FOR RELEASE ON BAIL Bobbi C. Sternheim Law Of
Court noted, the Court lacked "a clear picture of Ms. Maxwell's finances and the resources available to her."
idie 117132 i lakfan25/23a g 0%0? W735f118 WILLIAM JULIE AVOCAT A LA COUR - ATTORNEY AT LAW extradition and other removals", ECtHR 12 April 2012, Babar Ahmad and Others v. the United Kingdom, no. 24027/07, §168). 23. France has no difficulty with deporting individuals who have lost French nationality by
S DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, v. 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. REPLY MEMORANDUM OF GHISLAINE MAXWELL pi SUPPORT OF HER THIRD MOTION FOR RAII Bobbi C. Sternheim Law Offices of Bobbi C. Stemhcim 33 West 19th Street - 4th Floor New York NY 10011 P
Page: EFTA00031918 →th Avenue Denver CO 80203 Phone: Attorneys for Ghislaine Maxwell EFTA00031918 --- PAGE BREAK --- Preli
Page: EFTA00031918 →The issue before the Court, as it has been since Ms. Maxwell's first bail application, is whether conditions
Page: EFTA00031919 →one: Attorneys for Ghislaine Maxwell EFTA00031918 --- PAGE BREAK --- Preliminary Statement The issue before the Court, as it has been since Ms. Maxwell's first bail application, is whether conditions exist that can reasonably assure Ms. Maxwell's appearance at trial. On her third application (the "
Page: EFTA00031919 →NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.0 150 East 10th Avenue Denver CO 80203 Phone: Attorneys for Ghislaine Maxwell East Building, where Ms. Maxwell is detained, have been reviewed by an HVAC expert retained by the Federal Defenders of New York and have been charac
Page: EFTA00031928 →Entities connected to both Ghislaine Maxwell and Babar Ahmad

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
United States
LOCATION
Michael Cohen
PERSON
Department of Justice
ORGANIZATIONJeffrey Pagliuca
PERSON
Denver
LOCATION
David Rodgers
PERSON
Colorado
LOCATIONCohen & Gresser LLP
ORGANIZATION
United Kingdom
LOCATIONFederal Bureau of Prisons
ORGANIZATION
the United States District Court
ORGANIZATIONMORGAN & FOREMAN
ORGANIZATIONthe Northern District
LOCATIONPretrial Services
ORGANIZATION
Peter Thiel
PERSONJulie
PERSONDuffey
PERSONthe Requested State
LOCATION