Epstein Secrets

LAINE MAXWELL JEFFREY EPSTEIN, PRINCE ANDREW, 3/22/20 EFTA00084370 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 6 of 161 Socialite Ghislaine Maxwell 'groped a 16-year-old girl during a naked massage,' victims' lawyer says O dailvmaitco.uk/news/article-8163681/Socialite-Ghislaine-Maxwell-hroped-16-

ummer of 1994 at Michigan's Interlochen Arts Camp, where she was In voice training, according to newly filed court papers suing Epstein's estate and Maxwell. The duo quickly took her under their wing, taking her to movies and on shopping trips in her home state of Florida and all the while grooming her

City — near his own townhouse, where he would allegedly rape her the next year. MAIM Feds finally start investigating Jeffrey Epstein's gal pal Ghislaine Maxwell "In 1997, while at Epstein's townhouse on 9 East 71st Street in the City of New York. Epstein asked 17-year-old Doe if she had a boyfriend

By Jams mu and Pelt Nbadta My 10.2020.2:06AM • mm rrad 11 ir • Obtains Maxwal behind bars as now details emerge Jeffrey Epstein's ex-girlfriend Ghatoine Maxwell is accused of facilitating Epstein's sex crimes by ',sting him Mafia, groom and ultimately abuse three unnamed teens between 2994 and 1997. Ghislai

case. "Denial of a stay, particularly a stay of Ms. Maxwell's deposition, pending outcome of the criminal inv

Audrey Strauss called the sex abuse described in the Maxwell case "the prequel" to the charges they lodged la

1 New York prosecutors said in a filing Monday this was evidence that Maxwell was 'skilled at living in hiding' and should be denied bail Proposed Bail Conditions. In light of the above, we propose the following bail conditions, which are consistent with those that courts in this Circuit have imposed in analog

by the COVID-19 Pandemic Mandate the Release of Ms. Maxwell. 5 II. The Government Has Not Carried Its Burd

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 C

URT 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 R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10

dmission pending) Laura A. Menninger HADDON, MORGAN & FORMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: 303-831-7364 Attorneys for Ghislaine Maxwell EFTA00066317 Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 2 of 26 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 ARGUMENT 5 I. T

, Daily Mail (Aug. 10, 2019) https:/Avww.dailymail.co.uk/news/arlicle-7344765/Spotlight-turns- Jeffrey-Epsteins-fixer-Ghislaine-Maxwell-suicide.html• Ghislaine Maxwell• the woman accused of helping Jeffrey Epstein groom girls, The Guardian (Aug. 12, 2019), htlps://www.theguardian.com/us-news/2019/aug/12/ghislaine- m

duct that is roughly twenty-five years old, is not persuasive and does not alter the bail analysis. (See infra Section II, pages 9 to 21). Proposed Bail Conditions. In light of the above, we propose the following bail conditions, which are consistent with those that courts in this Circuit have imposed in analog

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 C

URT 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 R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10

dmission pending) Laura A. Menninger HADDON, MORGAN & FORMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: 303-831-7364 Attorneys for Ghislaine Maxwell EFTA00083324 Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 2 of 26 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 ARGUMENT 5 I. T

by the COVID-19 Pandemic Mandate the Release of Ms. Maxwell. 5 II. The Government Has Not Carried Its Burd

, Daily Mail (Aug. 10, 2019) https:/Avww.dailymail.co.uk/news/arlicle-7344765/Spotlight-turns- Jeffrey-Epsteins-fixer-Ghislaine-Maxwell-suicide.html• Ghislaine Maxwell• the woman accused of helping Jeffrey Epstein groom girls, The Guardian (Aug. 12, 2019), htlps://www.theguardian.com/us-news/2019/aug/12/ghislaine- m

duct that is roughly twenty-five years old, is not persuasive and does not alter the bail analysis. (See infra Section II, pages 9 to 21). Proposed Bail Conditions. In light of the above, we propose the following bail conditions, which are consistent with those that courts in this Circuit have imposed in analog

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 C

URT 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 R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10

dmission pending) Laura A. Menninger HADDON, MORGAN & FORMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: 303-831-7364 Attorneys for Ghislaine Maxwell EFTA00102661 Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 2 of 26 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 ARGUMENT 5 I. T

by the COVID-19 Pandemic Mandate the Release of Ms. Maxwell. 5 II. The Government Has Not Carried Its Burd

, Daily Mail (Aug. 10, 2019) https:/Avww.dailymail.co.uk/news/arlicle-7344765/Spotlight-turns- Jeffrey-Epsteins-fixer-Ghislaine-Maxwell-suicide.html• Ghislaine Maxwell• the woman accused of helping Jeffrey Epstein groom girls, The Guardian (Aug. 12, 2019), htlps://www.theguardian.com/us-news/2019/aug/12/ghislaine- m

duct that is roughly twenty-five years old, is not persuasive and does not alter the bail analysis. (See infra Section II, pages 9 to 21). Proposed Bail Conditions. In light of the above, we propose the following bail conditions, which are consistent with those that courts in this Circuit have imposed in analog

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 C

URT 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 R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10

0) 6 Statutes 18 U.S.C. § 3142 passim iii EFTA00104628 Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 5 of 26 PRELIMINARY STATEMENT Ghislaine Maxwell respectfully submits this Memorandum in Opposition to the government's July 2, 2020 Memorandum in Support of Detention ("Gov. Mem."). It is difficu

by the COVID-19 Pandemic Mandate the Release of Ms. Maxwell. 5 II. The Government Has Not Carried Its Burd

, Daily Mail (Aug. 10, 2019) https:/Avww.dailymail.co.uk/news/arlicle-7344765/Spotlight-turns- Jeffrey-Epsteins-fixer-Ghislaine-Maxwell-suicide.html• Ghislaine Maxwell• the woman accused of helping Jeffrey Epstein groom girls, The Guardian (Aug. 12, 2019), htlps://www.theguardian.com/us-news/2019/aug/12/ghislaine- m

duct that is roughly twenty-five years old, is not persuasive and does not alter the bail analysis. (See infra Section II, pages 9 to 21). Proposed Bail Conditions. In light of the above, we propose the following bail conditions, which are consistent with those that courts in this Circuit have imposed in analog

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 C

URT 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 R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10

dmission pending) Laura A. Menninger HADDON, MORGAN & FORMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: 303-831-7364 Attorneys for Ghislaine Maxwell EFTA00151417 Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 2 of 26 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 ARGUMENT 5 I. T

by the COVID-19 Pandemic Mandate the Release of Ms. Maxwell. 5 II. The Government Has Not Carried Its Burd

, Daily Mail (Aug. 10, 2019) https:/Avww.dailymail.co.uk/news/arlicle-7344765/Spotlight-turns- Jeffrey-Epsteins-fixer-Ghislaine-Maxwell-suicide.html• Ghislaine Maxwell• the woman accused of helping Jeffrey Epstein groom girls, The Guardian (Aug. 12, 2019), htlps://www.theguardian.com/us-news/2019/aug/12/ghislaine- m

duct that is roughly twenty-five years old, is not persuasive and does not alter the bail analysis. (See infra Section II, pages 9 to 21). Proposed Bail Conditions. In light of the above, we propose the following bail conditions, which are consistent with those that courts in this Circuit have imposed in analog

by the COVID-19 Pandemic Mandate the Release of Ms. Maxwell. 5 II. The Government Has Not Carried Its Burd

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 C

URT 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 R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10

dmission pending) Laura A. Menninger HADDON, MORGAN & FORMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: 303-831-7364 Attorneys for Ghislaine Maxwell EFTA01653624 Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 2 of 26 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 ARGUMENT 5 I. T

, Daily Mail (Aug. 10, 2019) https:/Avww.dailymail.co.uk/news/arlicle-7344765/Spotlight-turns- Jeffrey-Epsteins-fixer-Ghislaine-Maxwell-suicide.html• Ghislaine Maxwell• the woman accused of helping Jeffrey Epstein groom girls, The Guardian (Aug. 12, 2019), htlps://www.theguardian.com/us-news/2019/aug/12/ghislaine- m

duct that is roughly twenty-five years old, is not persuasive and does not alter the bail analysis. (See infra Section II, pages 9 to 21). Proposed Bail Conditions. In light of the above, we propose the following bail conditions, which are consistent with those that courts in this Circuit have imposed in analog

ELL, 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

v. GHISLAINE MAXWELL, Appellant. On Appeal from the United States District Court for the Southern District of New York, 20-CR-330 (MN) Appellant Ghislaine Maxwell's Motion for Pretrial Release David Oscar Markus MARKUS/MOSS PLLC 40 N.W. Third Street Penthouse One Miami, Florida 33128 EFTA00093045 Case 21-

3068296, Page2 of 31 No. 21-770 & 21-58 In the Mufti) Sates' Court of 5Appeats for the £ieconb (Circuit UNITED STATES OF AMERICA. Appellee, v. GHISLAINE MAXWELL, Appellant. On Appeal from the United States District Court for the Southern District of New York, 20-CR-330 (MN) Appellant Ghislaine Max

nimous that such conditions produce mental deterioration, which prevents her from effective participation in trial preparation. Worse, even if Ms. Maxwell were able to be fully alert and mentally acute, she must review over 2,500,000 prosecution pages on a gutted computer, which does not have the abil

rticipation in trial preparation. Worse, even if Ms. Maxwell were able to be fully alert and mentally acute,

duct that is roughly twenty-five years old, is not persuasive and does not alter the bail analysis. (See infra Section II, pages 9 to 21). Proposed Bail Conditions. In light of the above, we propose the following bail conditions, which are consistent with those that courts in this Circuit have imposed in analog