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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 OF GHISLAINE MAXWELL IN SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. E
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 SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP New York, NY 10022 Phone: Jeffrey S. Pagliuc
DDON, MORGAN & FOREMAN P.C. Denver, CO 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim New York, NY 10011 Phone: Attorneys for Ghislaine Maxwell EFTA00094289 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 ARGUMENT 7 I. Reconsideration of the Court's Bail Decision is Appropriate Under
is Appropriate Under 18 U.S.C. § 3142(O 7 II. Ms. Maxwell Should Be Granted Bail Under the Proposed Strict
e to an August 14, 2019 news report that Ms. Maxwell might be living in Massachusetts, one person wrote: SHE'S HERE in #Massachusetts ?! The bitch #GhislaineMaxwell who #SexTrafficked young girls for #Epstein ?!?! Why the hell isn't she being brought in for questioning @ManchesterMAPD ?! WE DO NOT WANT HER HER
f Matthew Hellyer Exhibit T. Extradition Waivers Exhibit U. UK Extradition Opinion Exhibit V. France Extradition Opinion Exhibit W. Letter of Emily Waitt Exhibit X. Letter of Simon Lyons EFTA00094294 PRELIMINARY STATEMENT Ghislaine Maxwell respectfully submits this Memorandum in Support of her Re
, 2020 Honorable Alison J. Nathan United States District Judge United States Courthouse 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell 20 Cr. 330 (AJN) Dear Judge Nathan, I am writing this letter on behalf of Ghislaine Maxwell, a woman who I grew up knowing and looking up to. Ghi
ell 20 Cr. 330 (AJN) Dear Judge Nathan, I am writing this letter on behalf of Ghislaine Maxwell, a woman who I grew up knowing and looking up to. Ghislaine dated and lived with my father from when I was 10- 17 years old and we continue to be in touch today. I do not write this to discuss the charges ag
gainst Ghislaine Maxwell, to plead that she is innocent or argue that she is guilty. I am simply hoping to offer a more well-rounded picture of Ms. Maxwell as a person outside of the opinions of the media. As a kid, I saw Ghislaine as an example of a strong, caring woman. I have fond memories of her dri
y hoping to offer a more well-rounded picture of Ms. Maxwell as a person outside of the opinions of the media.
l it necessary. Whatever the outcome, I felt it was important for me to share my unique perspective and stand up for what I believe in. Sincerely, Emily Waitt EFTA00065582
Review of individuals who submitted letters for Maxwell 1. Scott Borgerson a. Accurint: i. Scott Borgerson iii. SSN: iv. v. b. NYPD Checks: Negative 2. Isabel Maxwell a. Accurint: i. Isabel Maxwe
PP: iv. Last Known Travel: 2/16/2010 INBOUND from Belize City to Miami, Intl b. Identifiers: i. Phone: ii. Email: c. NYPD Checks: Negative 16. Emily Waitt (Maxwell and ted wait) a. Accurint: Emily R Waitt SSN: (Feb 1999-Nov 2020) b. TECS i. Emily Rose Waitt ii. DOB: iii. US PP: c. NYPD Checks:
Entities connected to both Ghislaine Maxwell and Emily Waitt