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,

orandum Opinion and Order Respectfully submitted, MARKUS/MOSS PLLC 40 N.W. Third Street Penthouse One markuslaw.com By: /s/ David Oscar Markus DAVID OSCAR MARKUS Florida Bar Number 119318 [email protected] CERTIFICATE OF SERVICE I CERTIFY that a true and correct copy of the foregoing was e-filed

. GHISLAINE MAXWELL, Appellant. On Appeal from the United States District Court for the Southern District of New York, 20-CR-330 (AJN) Appellant Ghislaine Maxwell's Renewed Motion for Pretrial Release Leah S. Saffian David Oscar Markus LAW OFFICES OF LEAH SAFFIAN *Counsel of Record ME- markuslaw.com EFTA00

I2-13) EFTA00089451 No. 21-770 & 21-58 In the ZiRita) *tates Court of Apprat5 for the *mufti 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 (AJN) Appellant Ghislaine Ma

for bond (see Ex. A, Order, April 27, 2021), it appeared concerned with the conditions of her confinement during oral argument and instructed Ms. Maxwell that "[t]o the extent Appellant seeks relief specific to her sleeping conditions, such request should be addressed to the District Court." (Id.).

uld be addressed to the District Court." (Id.). Ms. Maxwell did just that, explaining again to the trial judg

SAFFIAN MARKUS/MOSS PLLC By: Is/ /s/ Leah S. Saffian LEAH S. SAFFIAN California Bar Number 11 I. " markuslaw.com By: Is/ David Oscar Markus DAVID OSCAR MARKUS Florida Bar Number [email protected] EFTA00089463 CERTIFICATE OF COMPLIANCE I CERTIFY that this petition complies with the type-volu

. GHISLAINE MAXWELL, Appellant. On Appeal from the United States District Court for the Southern District of New York, 20-CR-330 (AJN) Appellant Ghislaine Maxwell's Renewed Motion for Pretrial Release Leah S. Saffian LAW OFFICES OF LEAH SAFFIAN 15546 Meadowgate Road Encino, California 91436-3429 Tel: (858)4

21, 3102450, Paget of 14 No. 21-770 & 21-58 In the Malta *tates Court of Appeat5 for the *tomb 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 (AJN) Appellant Ghislaine Ma

for bond (see Ex. A, Order, April 27, 2021), it appeared concerned with the conditions of her confinement during oral argument and instructed Ms. Maxwell that "[t]o the extent Appellant seeks relief specific to her sleeping conditions, such request should be addressed to the District Court." (Id.).

uld be addressed to the District Court." (Id.). Ms. Maxwell did just that, explaining again to the trial judg

California Bar Number 121796 11 MARKUS/MOSS PLLC *Counsel of Record 40 N.W. Third Street, PH 1 Miami, Florida 33128 By: Is/ David Oscar Markus DAVID OSCAR MARKUS Florida Bar Number 19318 EFTA00096531 Case 21-58, Document 89-1, 05/17/2021, 3102450. Page14 of 14 CERTIFICATE OF COMPLIANCE I CERTIFY t