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

Ms. Maxwell's Presence in Court 34 EFTA00065717 G. The Alternative to Bail Is Confinement Under Oppressive Conditions that Impact Ms. Maxwell's Health and Ability to Prepare Her Defense 35 CONCLUSION 38 ii EFTA00065718 TABLE OF AUTHORITIES Page(s) Cases United States v. Boustani, 932 F.3d 79 (2d Cir. 2019) 3 United State

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

Ms. Maxwell's Presence in Court 34 EFTA00154513 G. The Alternative to Bail Is Confinement Under Oppressive Conditions that Impact Ms. Maxwell's Health and Ability to Prepare Her Defense 35 CONCLUSION 38 ii EFTA00154514 TABLE OF AUTHORITIES Page(s) Cases United States v. Boustani, 932 F.3d 79 (2d Cir. 2019) 3 United State

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

Ms. Maxwell's Presence in Court 34 EFTA00094290 G. The Alternative to Bail Is Confinement Under Oppressive Conditions that Impact Ms. Maxwell's Health and Ability to Prepare Her Defense 35 CONCLUSION 38 ii EFTA00094291 TABLE OF AUTHORITIES Page(s) Cases United States v. Boustani, 932 F.3d 79 (2d Cir. 2019) 3 United State

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

1136tifMaiht:02 El lae6129.4/2thg Phfre c10 (51515 G. The Alternative to Bail Is Confinement Under Oppressive Conditions that Impact Ms. Maxwell's Health and Ability to Prepare Her Defense 35 CONCLUSION 38 EFTA00093218 aste12207a0OITEMOAMI lattatitegict02 Fireel61214/Rag Pt* 4I 2515 TABLE OF AUTHORITIES Page(s) Cases United St

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

well will not do that, and should be granted bail. G. The Alternative to Bail Is Confinement Under Oppressive Conditions that Impact Ms. Maxwell's Health and Ability to Prepare Her Defense Granting bail to Ms. Maxwell is all the more appropriate and necessary because the past few months have shown that Ms. Maxwell cannot adequately pa