Epstein Secrets

amplified by the defendant's extensive international ties, her citizenship in two foreign countries, her wealth, and her lack of meaningful ties to the United States. In short, Maxwell has three passports, large sums of money, extensive international connections, and absolutely no reason to stay in the United Sta

ential sentence, the more probable the flight risk is, especially considering the strong case of the government . . . .") (quoting United States v. Alindato—Perez, 627 F. Supp. 2d 58, 66 (D.P.R. 2009)). Here, the defendant is facing a statutory maximum of decades in prison. This fact alone would provide

amplified by the defendant's extensive international ties, her citizenship in two foreign countries, her wealth, and her lack of meaningful ties to the United States. In short, Maxwell has three passports, large sums of money, extensive international connections, and absolutely no reason to stay in the United Sta

ential sentence, the more probable the flight risk is, especially considering the strong case of the government . . . .") (quoting United States v. Alindato—Perez, 627 F. Supp. 2d 58, 66 (D.P.R. 2009)). Here, the defendant is facing a statutory maximum of decades in prison. This fact alone would provide

amplified by the defendant's extensive international ties, her citizenship in two foreign countries, her wealth, and her lack of meaningful ties to the United States. In short, Maxwell has three passports, large sums of money, extensive international connections, and absolutely no reason to stay in the United Sta

ential sentence, the more probable the flight risk is, especially considering the strong case of the government . . . .") (quoting United States v. Alindato—Perez, 627 F. Supp. 2d 58, 66 (D.P.R. 2009)). Here, the defendant is facing a statutory maximum of decades in prison. This fact alone would provide

amplified by the defendant's extensive international ties, her citizenship in two foreign countries, her wealth, and her lack of meaningful ties to the United States. In short, Maxwell has three passports, large sums of money, extensive international connections, and absolutely no reason to stay in the United Sta

potential sentence, the more probable the flight risk is, especially considering the strong case of the government . .") (quoting United States v. Alindato—Perez, 627 F. Supp. 2d 58, 66 (D.P.R. 2009)). Here, the defendant is facing a statutory maximum of decades in prison. This fact alone would provide

amplified by the defendant's extensive international ties, her citizenship in two foreign countries, her wealth, and her lack of meaningful ties to the United States. In short, Maxwell has three passports, large sums of money, extensive international connections, and absolutely no reason to stay in the United Sta

ential sentence, the more probable the flight risk is, especially considering the strong case of the government . . . .") (quoting United States v. Alindato—Perez, 627 F. Supp. 2d 58, 66 (D.P.R. 2009)). Here, the defendant is facing a statutory maximum of decades in prison. This fact alone would provide

Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 1 of 26 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN OPPOSITION TO THE GOVERNMENT'S MOTION FOR DETENTION

AK --- Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 6 of 26 Background. Ms. Maxwell, 58, is a naturalized U.S. citizen who has resided in the United States since 1991. She is also a citizen of France, where she was born, and of the United Kingdom, where she was educated and spent her childhood and forma

ngly, the asserted potential for a long sentence does not meet the government's burden of persuasion.14 14 The government relies on United States v. Alindato-Perez, 627 F. Supp. 2d 58, 66 (D.P.R. 2009), cited approvingly by United States v. Moscaritolo, No. 10 Cr. 4 (JL), 2010 WL 309679, at •2 (D.N.H. Jan