Epstein Secrets

ISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, v. 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER THIRD MOTION FOR RAIL Bobbi C. Sternheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York NY

URT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, v. 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER THIRD MOTION FOR RAIL Bobbi C. Sternheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York NY 10011 P

pursuant to a request from Olivier Laude, a partner at the French firm Laude Esquier Champey acting on behalf of Cohen & Gresser LLP as counsel for Ms Ghislaine Maxwell. The request was made in the context of ongoing bail proceedings involving Ms Maxwell in the United States of America (hereafter "USA"), where Ms M

The issue before the Court, as it has been since Ms. Maxwell's first bail application, is whether conditions

crimes that may give rise to a deprivation of citizenship. For example, a dual French-Algerian citizen named Djamel Beghal was recently deported to Algeria after he was convicted of terrorist offences and subsequently deprived of his French nationality'. 24. While in custody in France, Djamcl Beghal wa

ant presented to the Court at the initial bail hearing was undisputedly incomplete, and as the Court noted, the Court lacked "a clear picture of Ms. Maxwell's finances and the resources available to her." Tr. at 86 87. The Defendant has now presented to the Court what is perhaps a more thorough report o

pursuant to a request from Olivier Laude, a partner at the French firm Laude Esquier Champey acting on behalf of Cohen & Gresser LLP as counsel for Ms Ghislaine Maxwell. The request was made in the context of ongoing bail proceedings involving Ms Maxwell in the United States of America (hereafter "USA"), where Ms M

207a0063390eNt Thaatiallat 1 [email protected] UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S THIRD MOTION FOR RELEASE ON BAIL Bobbi C. Sternheim Law Of

Court noted, the Court lacked "a clear picture of Ms. Maxwell's finances and the resources available to her."

crimes that may give rise to a deprivation of citizenship. For example, a dual French-Algerian citizen named Djamel Beghal was recently deported to Algeria after he was convicted of terrorist offences and subsequently deprived of his French nationality'. 24. While in custody in France, Djamel Beghal wa

ther King, Jr., Stokely Carmichael, H. Rap Brown, Maxwell Stanford and Elijah Muhammad. Part of the COINT

nary black nationalist and socialist organization active in the United States from 1966 until 1982, with its only international chapter operating in Algeria from 1969 until 1972. Original six members of the Black Panther Party included Elbert "Big Man" Howard, Huey P. Newton (Defense Minister), Sherwin

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S DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, v. 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. REPLY MEMORANDUM OF GHISLAINE MAXWELL pi SUPPORT OF HER THIRD MOTION FOR RAII Bobbi C. Sternheim Law Offices of Bobbi C. Stemhcim 33 West 19th Street - 4th Floor New York NY 10011 P

th Avenue Denver CO 80203 Phone: Attorneys for Ghislaine Maxwell EFTA00031918 --- PAGE BREAK --- Preli

The issue before the Court, as it has been since Ms. Maxwell's first bail application, is whether conditions

one: Attorneys for Ghislaine Maxwell EFTA00031918 --- PAGE BREAK --- Preliminary Statement The issue before the Court, as it has been since Ms. Maxwell's first bail application, is whether conditions exist that can reasonably assure Ms. Maxwell's appearance at trial. On her third application (the "

NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.0 150 East 10th Avenue Denver CO 80203 Phone: Attorneys for Ghislaine Maxwell East Building, where Ms. Maxwell is detained, have been reviewed by an HVAC expert retained by the Federal Defenders of New York and have been charac