Epstein Secrets

o. 02 CR. 756 LMM, 2003 WL 21196846 (S.D.N.Y. May 21, 2003) 8 United States v. Salvagno, 314 F. Supp. 2d 115 (N.D.N.Y. 2004) 27 United States v. Stephens, 447 F. Supp. 3d 63 (S.D.N.Y. 2020) 7, 38 United States v. Ward, 63 F. Supp. 2d 1203 (C.D. Cal. 1999) 7 iii EFTA00065719 Statutes 18 U.S.C.

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

Her Arrest 18 1. Ms. Maxwell Was Trying to Protect Herself from a Media Frenzy and from Physical Threats 18 2. Ms. Maxwell's Counsel Was in Regular Contact with the Government Prior to Her Arrest 22 3. Ms. Maxwell Did Not Try to Avoid Arrest, Nor Was She "Good At" Hiding 23 D. Ms. Maxwell Has Wai

o. 02 CR. 756 LMM, 2003 WL 21196846 (S.D.N.Y. May 21, 2003) 8 United States v. Salvagno, 314 F. Supp. 2d 115 (N.D.N.Y. 2004) 27 United States v. Stephens, 447 F. Supp. 3d 63 (S.D.N.Y. 2020) 7, 38 United States v. Ward, 63 F. Supp. 2d 1203 (C.D. Cal. 1999) 7 iii EFTA00154515 Statutes 18 U.S.C.

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

Her Arrest 18 1. Ms. Maxwell Was Trying to Protect Herself from a Media Frenzy and from Physical Threats 18 2. Ms. Maxwell's Counsel Was in Regular Contact with the Government Prior to Her Arrest 22 3. Ms. Maxwell Did Not Try to Avoid Arrest, Nor Was She "Good At" Hiding 23 D. Ms. Maxwell Has Wai

o. 02 CR. 756 LMM, 2003 WL 21196846 (S.D.N.Y. May 21, 2003) 8 United States v. Salvagno, 314 F. Supp. 2d 115 (N.D.N.Y. 2004) 27 United States v. Stephens, 447 F. Supp. 3d 63 (S.D.N.Y. 2020) 7, 38 United States v. Ward, 63 F. Supp. 2d 1203 (C.D. Cal. 1999) 7 iii EFTA00094292 Statutes 18 U.S.C.

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

8 1. Ms. Maxwell Was Trying to Protect Herself and Her Family from a Media Frenzy and from Physical Threats 18 2. Ms. Maxwell's Counsel Was in Regular Contact with the Government Prior to Her Arrest 22 3. Ms. Maxwell Did Not Try to Avoid Arrest, Nor Was She "Good At" Hiding 23 D. Ms. Maxwell Has Wai

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

ent Before Her Arrest 18 1. Ms. Maxwell Was Trying to Protect Herself a Media Frenzy and from Physical Threats 2. Ms. Maxwell's Counsel Was in Regular Contact with the Government Prior to Her Arrest from 3. Ms. Maxwell Did Not Try to Avoid Arrest, Nor Was She "Good At" Hiding D. Ms. Maxwell Has Waive