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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
t. x 20 Cr. 330 (AJN) MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S THIRD MOTION FOR RELEASE ON BAIL Bobbi C. Stern
ell EFTA00077263 INTRODUCTION Ghislaine Maxwell respectfully submits this Memorandum in Support of her Third Motion for Release on Bail. As Ms. Maxwell has stated on numerous occasions and reaffirms here: she has no intention or desire to leave this country. She is an American citizen, has lived in
ort of her Third Motion for Release on Bail. As Ms. Maxwell has stated on numerous occasions and reaffirms he
ceeds that result from the pending sale 1 The Personal Account is identified as Account Ion page 9 of the Financial Report annexed to Ms. Maxwell's Renewed Bail Application. (See Dkt. 97, Exhibit 0.) 5 EFTA00077267 of Ms. Maxwell's London house and any other assets, excluding salary, hereinafter acquired. The asset
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
t. x 20 Cr. 330 (AJN) MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S THIRD MOTION FOR RELEASE ON BAIL Bobbi C. Stern
ell EFTA00083712 INTRODUCTION Ghislaine Maxwell respectfully submits this Memorandum in Support of her Third Motion for Release on Bail. As Ms. Maxwell has stated on numerous occasions and reaffirms here: she has no intention or desire to leave this country. She is an American citizen, has lived in
ort of her Third Motion for Release on Bail. As Ms. Maxwell has stated on numerous occasions and reaffirms he
ceeds that result from the pending sale 1 The Personal Account is identified as Account Ion page 9 of the Financial Report annexed to Ms. Maxwell's Renewed Bail Application. (See Dkt. 97, Exhibit 0.) 5 EFTA00083716 of Ms. Maxwell's London house and any other assets, excluding salary, hereinafter acquired. The asset
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
t. x 20 Cr. 330 (AJN) MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S THIRD MOTION FOR RELEASE ON BAIL Bobbi C. Stern
ell EFTA00083701 INTRODUCTION Ghislaine Maxwell respectfully submits this Memorandum in Support of her Third Motion for Release on Bail. As Ms. Maxwell has stated on numerous occasions and reaffirms here: she has no intention or desire to leave this country. She is an American citizen, has lived in
ort of her Third Motion for Release on Bail. As Ms. Maxwell has stated on numerous occasions and reaffirms he
ceeds that result from the pending sale 1 The Personal Account is identified as Account Ion page 9 of the Financial Report annexed to Ms. Maxwell's Renewed Bail Application. (See Dkt. 97, Exhibit 0.) 5 EFTA00083705 of Ms. Maxwell's London house and any other assets, excluding salary, hereinafter acquired. The asset
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
t. x 20 Cr. 330 (AJN) MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S THIRD MOTION FOR RELEASE ON BAIL Bobbi C. Stern
ell EFTA00083790 INTRODUCTION Ghislaine Maxwell respectfully submits this Memorandum in Support of her Third Motion for Release on Bail. As Ms. Maxwell has stated on numerous occasions and reaffirms here: she has no intention or desire to leave this country. She is an American citizen, has lived in
ort of her Third Motion for Release on Bail. As Ms. Maxwell has stated on numerous occasions and reaffirms he
ceeds that result from the pending sale 1 The Personal Account is identified as Account Ion page 9 of the Financial Report annexed to Ms. Maxwell's Renewed Bail Application. (See Dkt. 97, Exhibit 0.) 5 EFTA00083794 of Ms. Maxwell's London house and any other assets, excluding salary, hereinafter acquired. The asset
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
t. x 20 Cr. 330 (AJN) MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S THIRD MOTION FOR RELEASE ON BAIL Bobbi C. Stern
ell EFTA00090990 INTRODUCTION Ghislaine Maxwell respectfully submits this Memorandum in Support of her Third Motion for Release on Bail. As Ms. Maxwell has stated on numerous occasions and reaffirms here: she has no intention or desire to leave this country. She is an American citizen, has lived in
ort of her Third Motion for Release on Bail. As Ms. Maxwell has stated on numerous occasions and reaffirms he
ceeds that result from the pending sale 1 The Personal Account is identified as Account Ion page 9 of the Financial Report annexed to Ms. Maxwell's Renewed Bail Application. (See Dkt. 97, Exhibit 0.) 5 EFTA00090994 of Ms. Maxwell's London house and any other assets, excluding salary, hereinafter acquired. The asset
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
t. x 20 Cr. 330 (AJN) MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S THIRD MOTION FOR RELEASE ON BAIL Bobbi C. Stern
ell EFTA00102090 INTRODUCTION Ghislaine Maxwell respectfully submits this Memorandum in Support of her Third Motion for Release on Bail. As Ms. Maxwell has stated on numerous occasions and reaffirms here: she has no intention or desire to leave this country. She is an American citizen, has lived in
ort of her Third Motion for Release on Bail. As Ms. Maxwell has stated on numerous occasions and reaffirms he
ceeds that result from the pending sale 1 The Personal Account is identified as Account Ion page 9 of the Financial Report annexed to Ms. Maxwell's Renewed Bail Application. (See Dkt. 97, Exhibit 0.) 5 EFTA00102094 of Ms. Maxwell's London house and any other assets, excluding salary, hereinafter acquired. The asset
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."
ceeds that result from the pending sale 1 The Personal Account is identified as Account Ion page 9 of the Financial Report annexed to Ms. Maxwell's Renewed Bail Application. (See Dkt. 97, Exhibit 0.) 5 EFTA00093356 GIate122(37006220,9A611 latfitigi2021,Riteilaritnifraeftjeiatif19 of Ms. Maxwell's London house and an
Entities connected to both Ghislaine Maxwell and Renewed Bail Application

Jeffrey Epstein
PERSON
United States
LOCATION
Michael Cohen
PERSONJeffrey Pagliuca
PERSON
Denver
LOCATION
John F. Kennedy
PERSON
Colorado
LOCATION
Richard Kahn
PERSONBobbi C. Sternheim
PERSONCohen & Gresser LLP
ORGANIZATION
United Kingdom
LOCATIONR. Everdell
PERSONMORGAN & FOREMAN
ORGANIZATIONthe Northern District
LOCATIONPretrial Services
ORGANIZATIONPetrov
PERSONDuffey
PERSON
Dominique Strauss-Kahn
PERSONWilliam S. Duffey
PERSONStrauss-Kahn's
PERSON