Epstein Secrets

2010) 18 United States v. Sabhnani, 493 F.3d 63 (2d Cir. 2007) 9, 10, 16, 18 United States v. Salerno, 481 U.S. 739 (1987) 9 United States v. Stephens, 15-CR-95 (MN), 2020 WL 1295155 (S.D.N.Y. Mar. 19, 2020) 5, 6, 7, 8 United States v. Peres, No. 3:20-CR-18-J-32JBT, 2020 WL 1042051 (M.D. Fla. Ma

d prepare for her defense will be significantly impaired and she will not be able to meaningfully participate in the preparation of her defense. In Stephens, the Court found that this factor required the defendant's release under 18 U.S.C. § 3142(i), which provides for temporary release based on a determ

n granted release subject to conditions), aff'd, 749 F. App'x 20 (2d Cir. 2018); United States v. Dreier, 596 F. Supp. 2d 831, 832 (S.D.N.Y. 2009) (Marc Dreier, accused of "colossal criminality" and alleged to be a "high flight risk," granted release subject to conditions); United States v. Madoff, 586 F. S

United States v. DiGiacomo, 746 F. Supp. 1176 (D. Mass. 1990) 14 United States v. Dominguez, 783 F.2d 702 (7th Cir. 1986) 10 United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009) 21 United States v. English, 629 F.3d 311 (2d Cir. 2011) 10, 11 ii EFTA00102663 Case 1:20-cr-00330-AJN

17 of 31 subject to the weight of federal power are always a special concern of the judiciary." Chandler, 2020 WL 1528120, at *2; United States v. Stephens, 447 F. Supp. 3d 65-67 (S.D.N.Y. 2020) (finding that "the obstacles the current public health crisis poses to the preparation of the Defendant's de

d prepare for her defense will be significantly impaired and she will not be able to meaningfully participate in the preparation of her defense. In Stephens, the Court found that this factor required the defendant's release under 18 U.S.C. § 3142(i), which provides for temporary release based on a determ

United States v. DiGiacomo, 746 F. Supp. 1176 (D. Mass. 1990) 14 United States v. Dominguez, 783 F.2d 702 (7th Cir. 1986) 10 United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009) 21 United States v. English, 629 F.3d 311 (2d Cir. 2011) 10, 11 ii EFTA00093092 cQ@&€i 'Is.rafåeffiAl,f

e foreign ties, are routinely granted bail so that they can effectively prepare for trial. Bernie Madoff. Harvey Weinstein. Bill Cosby. John Gotti. Marc Dreier. Dominique Strauss- Kahn. Ali Sadr. Adnan Khashoggi. Mahender Sabhnani. The list goes on and on. In each case, the court set reasonable conditions o

2010) 18 United States v. Sabhnani, 493 F.3d 63 (2d Cir. 2007) 9, 10, 16, 18 United States v. Salerno, 481 U.S. 739 (1987) 9 United States v. Stephens, 15-CR-95 (MN), 2020 WL 1295155 (S.D.N.Y. Mar. 19, 2020) 5, 6, 7, 8 United States v. Peres, No. 3:20-CR-18-J-32JBT, 2020 WL 1042051 (M.D. Fla. Ma

d prepare for her defense will be significantly impaired and she will not be able to meaningfully participate in the preparation of her defense. In Stephens, the Court found that this factor required the defendant's release under 18 U.S.C. § 3142(i), which provides for temporary release based on a determ

United States v. DiGiacomo, 746 F. Supp. 1176 (D. Mass. 1990) 14 United States v. Dominguez, 783 F.2d 702 (7th Cir. 1986) 10 United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009) 21 United States v. English, 629 F.3d 311 (2d Cir. 2011) 10, 11 ii EFTA00104627 Case 1:20-cr-00330-AJN

n granted release subject to conditions), aff'd, 749 F. App'x 20 (2d Cir. 2018); United States v. Dreier, 596 F. Supp. 2d 831, 832 (S.D.N.Y. 2009) (Marc Dreier, accused of "colossal criminality" and alleged to be a "high flight risk," granted release subject to conditions); United States v. Madoff, 586 F. S

2010) 18 United States v. Sabhnani, 493 F.3d 63 (2d Cir. 2007) 9, 10, 16, 18 United States v. Salerno, 481 U.S. 739 (1987) 9 United States v. Stephens, 15-CR-95 (MN), 2020 WL 1295155 (S.D.N.Y. Mar. 19, 2020) 5, 6, 7, 8 United States v. Peres, No. 3:20-CR-18-J-32JBT, 2020 WL 1042051 (M.D. Fla. Ma

d prepare for her defense will be significantly impaired and she will not be able to meaningfully participate in the preparation of her defense. In Stephens, the Court found that this factor required the defendant's release under 18 U.S.C. § 3142(i), which provides for temporary release based on a determ

United States v. DiGiacomo, 746 F. Supp. 1176 (D. Mass. 1990) 14 United States v. Dominguez, 783 F.2d 702 (7th Cir. 1986) 10 United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009) 21 United States v. English, 629 F.3d 311 (2d Cir. 2011) 10, 11 ii EFTA00066319 Case 1:20-cr-00330-AJN

n granted release subject to conditions), aff'd, 749 F. App'x 20 (2d Cir. 2018); United States v. Dreier, 596 F. Supp. 2d 831, 832 (S.D.N.Y. 2009) (Marc Dreier, accused of "colossal criminality" and alleged to be a "high flight risk," granted release subject to conditions); United States v. Madoff, 586 F. S

2010) 18 United States v. Sabhnani, 493 F.3d 63 (2d Cir. 2007) 9, 10, 16, 18 United States v. Salerno, 481 U.S. 739 (1987) 9 United States v. Stephens, 15-CR-95 (MN), 2020 WL 1295155 (S.D.N.Y. Mar. 19, 2020) 5, 6, 7, 8 United States v. Peres, No. 3:20-CR-18-J-32JBT, 2020 WL 1042051 (M.D. Fla. Ma

d prepare for her defense will be significantly impaired and she will not be able to meaningfully participate in the preparation of her defense. In Stephens, the Court found that this factor required the defendant's release under 18 U.S.C. § 3142(i), which provides for temporary release based on a determ

United States v. DiGiacomo, 746 F. Supp. 1176 (D. Mass. 1990) 14 United States v. Dominguez, 783 F.2d 702 (7th Cir. 1986) 10 United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009) 21 United States v. English, 629 F.3d 311 (2d Cir. 2011) 10, 11 ii EFTA00151419 Case 1:20-cr-00330-AJN

n granted release subject to conditions), aff'd, 749 F. App'x 20 (2d Cir. 2018); United States v. Dreier, 596 F. Supp. 2d 831, 832 (S.D.N.Y. 2009) (Marc Dreier, accused of "colossal criminality" and alleged to be a "high flight risk," granted release subject to conditions); United States v. Madoff, 586 F. S

2010) 18 United States v. Sabhnani, 493 F.3d 63 (2d Cir. 2007) 9, 10, 16, 18 United States v. Salerno, 481 U.S. 739 (1987) 9 United States v. Stephens, 15-CR-95 (MN), 2020 WL 1295155 (S.D.N.Y. Mar. 19, 2020) 5, 6, 7, 8 United States v. Peres, No. 3:20-CR-18-J-32JBT, 2020 WL 1042051 (M.D. Fla. Ma

d prepare for her defense will be significantly impaired and she will not be able to meaningfully participate in the preparation of her defense. In Stephens, the Court found that this factor required the defendant's release under 18 U.S.C. § 3142(i), which provides for temporary release based on a determ

United States v. DiGiacomo, 746 F. Supp. 1176 (D. Mass. 1990) 14 United States v. Dominguez, 783 F.2d 702 (7th Cir. 1986) 10 United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009) 21 United States v. English, 629 F.3d 311 (2d Cir. 2011) 10, 11 ii EFTA00083326 Case 1:20-cr-00330-AJN

n granted release subject to conditions), aff'd, 749 F. App'x 20 (2d Cir. 2018); United States v. Dreier, 596 F. Supp. 2d 831, 832 (S.D.N.Y. 2009) (Marc Dreier, accused of "colossal criminality" and alleged to be a "high flight risk," granted release subject to conditions); United States v. Madoff, 586 F. S

2010) 18 United States v. Sabhnani, 493 F.3d 63 (2d Cir. 2007) 9, 10, 16, 18 United States v. Salerno, 481 U.S. 739 (1987) 9 United States v. Stephens, 15-CR-95 (MN), 2020 WL 1295155 (S.D.N.Y. Mar. 19, 2020) 5, 6, 7, 8 United States v. Peres, No. 3:20-CR-18-J-32JBT, 2020 WL 1042051 (M.D. Fla. Ma

d prepare for her defense will be significantly impaired and she will not be able to meaningfully participate in the preparation of her defense. In Stephens, the Court found that this factor required the defendant's release under 18 U.S.C. § 3142(i), which provides for temporary release based on a determ

United States v. DiGiacomo, 746 F. Supp. 1176 (D. Mass. 1990) 14 United States v. Dominguez, 783 F.2d 702 (7th Cir. 1986) 10 United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009) 21 United States v. English, 629 F.3d 311 (2d Cir. 2011) 10, 11 ii EFTA01653626 Case 1:20-cr-00330-AJN

n granted release subject to conditions), aff'd, 749 F. App'x 20 (2d Cir. 2018); United States v. Dreier, 596 F. Supp. 2d 831, 832 (S.D.N.Y. 2009) (Marc Dreier, accused of "colossal criminality" and alleged to be a "high flight risk," granted release subject to conditions); United States v. Madoff, 586 F. S

al under the current pandemic situation is just not realistic. It is not meaningful. It is not fair. And I should say, as your Honor noted, in the Stephens case, we are not faulting the Bureau of Prisons. We are not faulting the Marshal Service. We understand they are doing the best they can under the

limits in the early instances your access to the client. It is complicated by the COVID crisis and the other factors your Honor has pointed out in Stephens and in Williams-Bethea, and so it is very hard for us to pull together this financial information, and we have done it as quickly as we could befor

at we did is we went through all the high profile cases in this courthouse in the past several years and other cases, cases like Medoff, cases like Dreier, cases like Esposito, where Judge Marrero ruled in 2018 relating to an alleged member of organized crime, and we went through those cases to find

al under the current pandemic situation is just not realistic. It is not meaningful. It is not fair. And I should say, as your Honor noted, in the Stephens case, we are not faulting the Bureau of Prisons. We are not faulting the Marshal Service. We understand they are doing the best they can under the

limits in the early instances your access to the client. It is complicated by the COVID crisis and the other factors your Honor has pointed out in Stephens and in Williams-Bethea, and so it is very hard for us to pull together this financial information, and we have done it as quickly as we could befor

at we did is we went through all the high profile cases in this courthouse in the past several years and other cases, cases like Medoff, cases like Dreier, cases like Esposito, where Judge Marrero ruled in 2018 relating to an alleged member of organized crime, and we went through those cases to find

on documents) with Ms. Maxwell and will further compromise her ability to prepare her defense. Moreover, as this Court observed in United States v. Stephens, if an outbreak occurs "substantial medical and security challenges would almost certainly arise." Stephens, 447 F. Supp. 3d at 65. We urge the Cour

inly arise." Stephens, 447 F. Supp. 3d at 65. We urge the Court to weigh the threat of COVID as a factor favoring release in this case, as it did in Stephens. CONCLUSION Ghislaine Maxwell is committed to defending herself and wants nothing more than to remain in this country, with her family and friends

WL 1456536 (3d Cir. July 13, 1999) 15 United States v. Cohen, No. C 10-00547, 2010 WL 5387757 n.11 (N.D. Cal. Dec. 20, 2010) 15 United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009) 27 United States v. English, 629 F.3d 311 (2d Cir. 2011) 7 United States v. Epstein, 155 F. Supp. 2d 323 (E.