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 Jeffrey S. Pagliuca Laura A. Menninger HADDO

ESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Ghislaine Maxwell EFTA00065716 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 ARGUMENT 7 1. 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

ra, and Mr. Raniere combined. ALL U.S. MEDIA COVERAGE COMPARISON (90 DAYS OF ARREST) 7.000 6.000 5.000 V t y 4,000 IJ moo 2.000 1.000 0 GIIISLAINE MAXWELL Hanmy Weirismo, rin*Trifirrnr,77.S 166171MITTETaUll Bill Cathy Jo Quln Gungn Lon Kolth Ramiro 21 EFTA00065742 2. Ms. Maxwell's Counsel Was i

hibit U). Mr. Perry has acted on behalf of many overseas governments in extradition proceedings; has 27 EFTA00065748 appeared in the High Court, House of Lords and Supreme Court in leading extradition cases; and has acted as an expert consultant to the Commonwealth Secretariat on international cooperation. (Id.). In 2011 an

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

hibit U). Mr. Perry has acted on behalf of many overseas governments in extradition proceedings; has 27 EFTA00094321 appeared in the High Court, House of Lords and Supreme Court in leading extradition cases; and has acted as an expert consultant to the Commonwealth Secretariat on international cooperation. (Id.). In 2011 an

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 Jeffrey S. Pagliuca Laura A. Menninger HADDO

ESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Ghislaine Maxwell EFTA00154512 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 ARGUMENT 7 1. 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

ra, and Mr. Raniere combined. ALL U.S. MEDIA COVERAGE COMPARISON (90 DAYS OF ARREST) 7.000 6.000 5.000 V t y 4,000 IJ moo 2.000 1.000 0 GIIISLAINE MAXWELL Hanmy Weirismo, rin*Trifirrnr,77.S 166171MITTETaUll Bill Cathy Jo Quln Gungn Lon Kolth Ramiro 21 EFTA00154538 2. Ms. Maxwell's Counsel Was i

hibit U). Mr. Perry has acted on behalf of many overseas governments in extradition proceedings; has 27 EFTA00154544 appeared in the High Court, House of Lords and Supreme Court in leading extradition cases; and has acted as an expert consultant to the Commonwealth Secretariat on international cooperation. (Id.). In 2011 an

ority of the bars that might be relied upon by Ms Maxwells require the extradition judge to make a finding

ts, a review that formed the basis of changes to the 2003 Extradition Act. (Id. Annex B ¶ 3.1). In Mr. Perry's opinion, it is "highly unlikely that Ghislaine Maxwell would be able successfully to resist extradition to the United States" in connection with this case. (Perry Rep. 12(e)). After concluding that none

ide any answer on this issue. 2 The DOJ Memorandum and the Peterson Case In support of its argument that the French government would not extradite Ms Ghislaine Maxwell to the USA, the government relies on the case of Mr Hans Peterson, a dual French American citizen whose extradition to the US was denied by

seding indictment dated 7 July 2020. In addition to those conclusions, the following three points may be made. 3. First, as noted in the Opinion2, Ms Maxwell's waiver of extradition would be admissible in any extradition proceedings in England and Wales. While such a document cannot compel a requested pers

r, CO 80203 Phone: Bobbi C. Sternheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: Attorneys for Ghislaine Maxwell II EFTA00093319 cailase:20-agloDacument ntlinfiAtIllf0891, 806E128B2Blage34figrl 3tI 4 Exhibit A EFTA00093320 Ckast.20-U-0003.00dblit DOditrehlei

ts in extradition proceedings; has 27 EFTA00093248 Cfissel211-Z744O3O4A2dit nbeuthMstl 91O2Fr i9822412Bag&lgea4a545 appeared in the High Court, House of Lords and Supreme Court in leading extradition cases; and has acted as an expert consultant to the Commonwealth Secretariat on international cooperation. (Id.). In 2011 an

ion is provided pursuant to instructions from Peters and Peters Solicitors LLP I dated 12 August 2020 in the context of bail proceedings relating to Ms Ghislaine Maxwell before the United States District Court, Southern District of New York. Subsequent instructions have confirmed that Ms Maxwell will execute a waive

of time since the alleged commission of the offences62. The courts have upheld orders for extradition in cases with similar timescales to those in Ms Maxwell's case, including two cases involving historic allegations of sexual offending where the relevant time period was 20 and 33 years. In both cases, the

d States prior to trial and in breach of bail. The following documents were annexed to the instructions: (a) Superseding Indictment United States v Ghislaine Maxwell dated 8 July 2020; (b) a transcript of the arraignment and bail hearing that took place on 14 July 2020; (c) the Motion to Detain the Defen

rior to trial and in breach of bail. The following documents were annexed to the instructions: (a) Superseding Indictment United States v Ghislaine Maxwell dated 8 July 2020; (b) a transcript of the arraignment and bail hearing that took place on 14 July 2020; (c) the Motion to Detain the Defendant date

tioners and is listed as such in the leading industry journals. He has acted on behalf of many overseas governments and appeared in the High Court, House of Lords and Supreme Court in the leading cases. He has acted as an expert consultant to the Commonwealth Secretariat on international co-operation and has advised overseas g

ion is provided pursuant to instructions from Peters and Peters Solicitors LLP I dated 12 August 2020 in the context of bail proceedings relating to Ms Ghislaine Maxwell before the United States District Court, Southern District of New York. Subsequent instructions have confirmed that Ms Maxwell will execute a waive

of time since the alleged commission of the offences62. The courts have upheld orders for extradition in cases with similar timescales to those in Ms Maxwell's case, including two cases involving historic allegations of sexual offending where the relevant time period was 20 and 33 years. In both cases, the

d States prior to trial and in breach of bail. The following documents were annexed to the instructions: (a) Superseding Indictment United States v Ghislaine Maxwell dated 8 July 2020; (b) a transcript of the arraignment and bail hearing that took place on 14 July 2020; (c) the Motion to Detain the Defen

rior to trial and in breach of bail. The following documents were annexed to the instructions: (a) Superseding Indictment United States v Ghislaine Maxwell dated 8 July 2020; (b) a transcript of the arraignment and bail hearing that took place on 14 July 2020; (c) the Motion to Detain the Defendant date

tioners and is listed as such in the leading industry journals. He has acted on behalf of many overseas governments and appeared in the High Court, House of Lords and Supreme Court in the leading cases. He has acted as an expert consultant to the Commonwealth Secretariat on international co-operation and has advised overseas g

ion is provided pursuant to instructions from Peters and Peters Solicitors LLP I dated 12 August 2020 in the context of bail proceedings relating to Ms Ghislaine Maxwell before the United States District Court, Southern District of New York. Subsequent instructions have confirmed that Ms Maxwell will execute a waive

of time since the alleged commission of the offences62. The courts have upheld orders for extradition in cases with similar timescales to those in Ms Maxwell's case, including two cases involving historic allegations of sexual offending where the relevant time period was 20 and 33 years. In both cases, the

d States prior to trial and in breach of bail. The following documents were annexed to the instructions: (a) Superseding Indictment United States v Ghislaine Maxwell dated 8 July 2020; (b) a transcript of the arraignment and bail hearing that took place on 14 July 2020; (c) the Motion to Detain the Defen

rior to trial and in breach of bail. The following documents were annexed to the instructions: (a) Superseding Indictment United States v Ghislaine Maxwell dated 8 July 2020; (b) a transcript of the arraignment and bail hearing that took place on 14 July 2020; (c) the Motion to Detain the Defendant date

tioners and is listed as such in the leading industry journals. He has acted on behalf of many overseas governments and appeared in the High Court, House of Lords and Supreme Court in the leading cases. He has acted as an expert consultant to the Commonwealth Secretariat on international co-operation and has advised overseas g