Epstein Secrets

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT X UNITED STATES OF AMERICA Dkt. Nos. 21-58, 21-770 Appellee, GHISLAINE MAXWELL, Defendant-Appellant. x AFFIRMATION IN OPPOSITION TO DEFENDANT'S RENEWED MOTION FOR PRETRIAL RELEASE STATE OF NEW YORK COUNTY OF NEW

District of New York, and I represent the United States of America in this matter. I submit this affirmation in opposition to defendant-appellant Ghislaine Maxwell's renewed motion for pretrial release following this Court's order, dated April 27, 2021, which denied Maxwell's prior motion for bail or temporary p

tion to defendant-appellant Ghislaine Maxwell's renewed motion for pretrial release following this Court's order, dated April 27, 2021, which denied Maxwell's prior motion for bail or temporary pretrial release and affirmed the District Court's orders denying such relief. EFTA00091595 PRELIMINARY STA

dge Nathan asking the District Court "to address Ms. Maxwell's sleeping conditions by directing the MDC to cea

ederal Rule of Appellate Procedure 32(g), the undersigned counsel hereby certifies that this opposition complies with the type-volume limitation of the Federal Rules of Appellate Procedure. As measured by the word processing system used to prepare this opposition, there are 5,164 words in this opposition. Is' Assistant United States A

20-2413-cv United States Court of Appeals for the Second Circuit VIRGINIA L GIUFFRE, —against- GHISLAINE MAXWELL, Plaintiff-Appellee, Defendant-Appellant. ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK 15-CV-74

s with the Government's position and opposes Defendant's motion to consolidate this appeal (the "civil appeal") with her appeal in United States v. Maxwell, No. 20-3061 (the "criminal appeal"). To the extent that Defendant's criminal appeal is not dismissed, Defendant's motion to consolidate should be

to one another. First, the issues presented in the criminal appeal have no bearing on the civil Citations to "D.E." refer to this Court's docket. Ghislaine Maxwell's Appendix is cited as "App." Virginia Giuffre's Supplemental Appendix is cited as "SA." EFTA00095336 appeal, and vice versa. As the Government's l

oad arguments lacking in specificity. App. 777 ("Ms. Maxwell's eleventh-hour request for reconsideration is de

Federal Rule of Appellate Procedure 32(g), the undersigned counsel hereby certifies that this response complies with the type-volume limitation of the Federal Rules of Appellate Procedure. As measured by the word processing system used to prepare this response, there are 1,222 words in this response. /s/Sigrid S. McCawley Certificat

ING ATTORNEY: Kerrie L. Campbell [name of attorney, whh firm, address. glione number and e-mail] KCampbell-Law, PLLC BOIES SCHILLER FLEXNER UP v. Maxwell OPPOSING ATTORNEY:Sigrid moe-awieY 1629 K St., NW, Suite 300, Washington, DC 20006 401 E. Las Olas Blvd. Suite 1200 Fort Lauderdale, FL, 33301 2

co-counsel with: (name/firm) Defendant-Appellee Ghislaine Maxwell IZIAmicus (in support of: (party/designation)

co-counsel with: (name/firm) Defendant-Appellee Ghislaine Maxwell IZIAmicus (in support of: (party/design

forcement reports in which identified Amicus as a co-conspirator of Epstein or a person with whom she had sexual relations. Pursuant to Rule 29 of the Federal Rules of Appellate Procedure and Second Circuit Local Rule 29.1(b), the undersigned counsel states: (a) that no party's counsel authored this brief in whole or in part; (b) tha