Epstein Secrets

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,

he Defendant's Renewed Motion for Release F' Doc. 103 Reply Memorandum of Ghislaine Maxwell in Support of Her Renewed Motion for Bail Doc. 106 Opinion & Order Doc. 160 Memorandum in Support of Ghislaine Maxwell's Third Motion for Release on Bail Doc. 165 The Government's Response in Opposition to Defen

New York, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (A.IN) Dear Judge Nathan:

rable Alison J. Nathan United States District Judge Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (A.IN) Dear Judge Nathan: The Government respectfully submits this letter in connection with the Court's Order of April 27, 2021, r

, New York 10007 Re: United States v. Ghislaine Maxwell, S2 20 Cr. 330 (A.IN) Dear Judge Nathan: The Go

SF, Dkt. No. 191 at 5). The defendant earlier moved to compel the Government to obtain and produce the diary to her, a motion the Court has denied. (Opinion & Order, Dkt. No. 207 at 29). As the Government explained in its opposition to that motion, the Government understands that Minor Victim-2 stopped writing

From: Subject: 20cr330, United States v. Maxwell Date: Mon, 23 Aug 2021 19:49:35 +0000 Attachments: 20cr330_Second_Ex_Parte_Mtn_Ex._1.pdf; 20cr330_Second_Ex 20cr330 Second Ex Parte_Mtn_Ex. 3.pdf;

Parte Mtn Ex. 2.pdf; _Parte_Mtn_Ex._4.pdf; to_F.R.Crim.P_17(c) Counsel: Per this Court's Order at Dkt. No. 325, please see the attached August 13 Opinion & Order and related motions papers. Please confirm receipt. Sincerely, Chambers of Judge Alison J. Nathan EFTA00040820

From: ' To: M: ilfS SANYS , Cc: Subject: FW: U.S. v. Maxwell, 20cr330, Opinion & Order Date: Fri, 25 Jun 2021 21:09:44 +0000 Attachments: 20cr330_Order 6.25.21.pdf; 20cr330_Sealed_Opinion_&_Order 6.25.21.pdf

From: ' To: M: ilfS SANYS , Cc: Subject: FW: U.S. v. Maxwell, 20cr330, Opinion & Order Date: Fri, 25 Jun 2021 21:09:44 +0000 Attachments: 20cr330_Order 6.25.21.pdf; 20cr330_Sealed_Opinion_&_Order 6.25.21.pdf Chiefs —Judge Nathan deni