Epstein Secrets

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

r of Kevin Maxwell Exhibit F. Letter of Pandora Maxwell Exhibit G. Letter of Ian Maxwell Exhibit H. Letter of Anne Holve Exhibit I. Letter of Chloe Maxwell Exhibit J. Letter of Helene Zimmerman Exhibit K. Letter of Jamie Hollomon Exhibit L. Letter of Matilda Munro Exhibit M. Letter of Jeff Paul R

Southern District of New York Unified States Courthouse 40 Foley Square New York, NY 10007 Your Honor. This statement is provided in support or GKslaine Maxwell's renewed application for bail and by way of character reference. I am one of Ghislalne's seven nieces. the daughter of Pandora and Kevin Maxwell, Gh

's renewed application for bail and by way of character reference. I am one of Ghislalne's seven nieces. the daughter of Pandora and Kevin Maxwell, Ghislaine's brother, and I am resident in Oxford in the UK. I am a single mother to my 2-year old son and I rent a small properly from my mother whom I live

Exhibit I EFTA00154411 Chloe Maxwell 1, December 2020 The Honorable Alison J. Nathan

our Honor. This statement is provided in support or GKslaine Maxwell's renewed application for bail and by way of character reference. I am one of Ghislalne's seven nieces. the daughter of Pandora and Kevin Maxwell, Ghislaine's brother, and I am resident in Oxford in the UK. I am a single mother to my 2-

life with her husband and his young children in the States. And I recall spending a wonderful Christmas with them in 2018 when they had invited an Ghisfaine's siblings and their children, together with her husbands family to spend quality family time together. Ghislaine was one of the original 'it' girl

Exhibit I EFTA00154411 Chloe Maxwell 1, December 2020 The Honorable Alison J. Nathan United States District Court Southern District of New York Unified States Courthouse 40 Foley S

February Commons by Lord Janner entrance St Stephen's gate with invitation card only, Ehud Olmert is guest speaker. Friday 7 February Saturday Karine Maxwell died in 1957 aged 3- 8 February Patrick Vlttoz, born 1945, he is 58 vacances scolaires for Nathalie up to 24 February Sunday 9 February Monday

30-10.45 Morning Coffee 10.45-12.15 Breakout Session - Law and Human Rights Breakout Session II - Shoah and the Love of God - Chairman Elisabeth Maxwell With James E. McNutt, Thomas More College (Cincinnati, OH), Bjorn Krondofer, St Mary's College of Maryland (St Mary's City, MD), Katharina von Kel

Maxwell born 1984 she is 19 years old Marthe Fleury born 1981 she is 23 years old Oping (Guadalupe) Aranar born 1928 she Is 76 years old Xmas eve Ghislaine Maxwell born 1961 she is 42 years old Xmas day Friday Boxing day EFTA00577568 26 December Saturday 27 December Sunday 28 December Monday 29 Decem

) Aranar born 1928 she Is 76 years old Xmas eve Ghislaine Maxwell born 1961 she is 42 years old Xmas day

rday 29 November Sunday 30 December Monday 1 December Tuesday 2 December Wednesday 3 December Giselle Malina born 1991 she is 12 years old Chloe Maxwell born 1989 she is 14 years old EFTA00577567 18 Thursday 4 December Friday 5 December Saturday 6 December Sunday 7 December Monday 8 Decem

Southern District of New York United States Courthouse 40 Foley Square New York, NY 10007 Your Honor. This statement is provided in support or GKslaine Maxwell's renewed application for bail and by way of character reference. I am one of Ghislaine's seven nieces. the daughter of Pandora and Kevin Maxwell, Gh

our Honor. This statement is provided in support or GKslaine Maxwell's renewed application for bail and by way of character reference. I am one of Ghislaine's seven nieces. the daughter of Pandora and Kevin Maxwell, GhiSlaine's brother, and I am resident in Oxford in the UK. I am a single mother to my 2-

Exhibit I EFTA00065632 Chloe Maxwell 1, December 2020 The Honorable Alison J. Nathan

Exhibit I EFTA00065632 Chloe Maxwell 1, December 2020 The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Sq

From: "Chloe Maxwell" <MIMI > To: "IMIMINI=" Subject: Re: Fwd: clik

From: "Chloe Maxwell" <MIMI > To: "IMIMINI=" Subject: Re: Fwd: clik on da teddi'z heart!! More den once! m Date: Mon, 02 Sep 2002 12:28:59 +0000 <x-flowed> here's my

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

ative 8. Anne Holve a. TECS i. DOB: ii. UK PP: iii. Last Known Travel: 5/23/2015 OUTBOUND from JFK, New York to UK b. NYPD Checks: Negative 9. Chloe Maxwell a. TECS i. DOB: ii. UK PP: iii. Last Known Travel: 9/30/2015 OUTBOUND from San Francisco to London b. NYPD Checks: Negative 10. Helene Zimmerm

To: From: Chloe Maxwell Sent: Mon 9/2/2002 12:28:59 PM Subject: Re: F

To: From: Chloe Maxwell Sent: Mon 9/2/2002 12:28:59 PM Subject: Re: Fwd: clik on da teddi'z heart!! More den oncell HI!! <x-flowed> here's my address! if you want til