Epstein Secrets

" Id. (emphasis in original). We submit that a similarly situated defendant who, like Ms. Maxwell, had no prior criminal record, significant ties to the United States, and a demonstrated lack of intent to flee the country, as well as numerous, supportive co-signers, but who did 20 EFTA00102684 Case 1:20-cr-0033

Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 21 of 26 France and the United Kingdom.13 Notably, two weeks ago, this Court recognized in United States v. Abdellatif El Mokadem, No. 19-CR-646 (AN), 2020 WL 3440515 (S.D.N.Y. June 23, 2020) that "concerns regarding risk of flight are mitigated by the

S.D.N.Y. Mar. 31, 2020) 8, 9 United States v. Conway, No. 4-11-70756 MAG(DMR), 2011 WL 3421321 (N.D. Cal. Aug. 3,2011) 10, 18 United States v. Crowell, No. 06-CR-291E(F), 2006 WL 3541736 (W.D.N.Y. Dec. 7, 2006) 11 United States v. Deutsch, No. 18-CR-502 (FB), 2020 WL 3577398 (E.D.N.Y. July 1, 2

" Id. (emphasis in original). We submit that a similarly situated defendant who, like Ms. Maxwell, had no prior criminal record, significant ties to the United States, and a demonstrated lack of intent to flee the country, as well as numerous, supportive co-signers, but who did 20 EFTA00104648 Case 1:20-cr-0033

Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 21 of 26 France and the United Kingdom.13 Notably, two weeks ago, this Court recognized in United States v. Abdellatif El Mokadem, No. 19-CR-646 (AN), 2020 WL 3440515 (S.D.N.Y. June 23, 2020) that "concerns regarding risk of flight are mitigated by the

S.D.N.Y. Mar. 31, 2020) 8, 9 United States v. Conway, No. 4-11-70756 MAG(DMR), 2011 WL 3421321 (N.D. Cal. Aug. 3,2011) 10, 18 United States v. Crowell, No. 06-CR-291E(F), 2006 WL 3541736 (W.D.N.Y. Dec. 7, 2006) 11 United States v. Deutsch, No. 18-CR-502 (FB), 2020 WL 3577398 (E.D.N.Y. July 1, 2

" Id. (emphasis in original). We submit that a similarly situated defendant who, like Ms. Maxwell, had no prior criminal record, significant ties to the United States, and a demonstrated lack of intent to flee the country, as well as numerous, supportive co-signers, but who did 20 EFTA00066340 Case 1:20-cr-0033

Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 21 of 26 France and the United Kingdom.13 Notably, two weeks ago, this Court recognized in United States v. Abdellatif El Mokadem, No. 19-CR-646 (AN), 2020 WL 3440515 (S.D.N.Y. June 23, 2020) that "concerns regarding risk of flight are mitigated by the

S.D.N.Y. Mar. 31, 2020) 8, 9 United States v. Conway, No. 4-11-70756 MAG(DMR), 2011 WL 3421321 (N.D. Cal. Aug. 3,2011) 10, 18 United States v. Crowell, No. 06-CR-291E(F), 2006 WL 3541736 (W.D.N.Y. Dec. 7, 2006) 11 United States v. Deutsch, No. 18-CR-502 (FB), 2020 WL 3577398 (E.D.N.Y. July 1, 2

" Id. (emphasis in original). We submit that a similarly situated defendant who, like Ms. Maxwell, had no prior criminal record, significant ties to the United States, and a demonstrated lack of intent to flee the country, as well as numerous, supportive co-signers, but who did 20 EFTA00151440 Case 1:20-cr-0033

Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 21 of 26 France and the United Kingdom.13 Notably, two weeks ago, this Court recognized in United States v. Abdellatif El Mokadem, No. 19-CR-646 (AN), 2020 WL 3440515 (S.D.N.Y. June 23, 2020) that "concerns regarding risk of flight are mitigated by the

S.D.N.Y. Mar. 31, 2020) 8, 9 United States v. Conway, No. 4-11-70756 MAG(DMR), 2011 WL 3421321 (N.D. Cal. Aug. 3,2011) 10, 18 United States v. Crowell, No. 06-CR-291E(F), 2006 WL 3541736 (W.D.N.Y. Dec. 7, 2006) 11 United States v. Deutsch, No. 18-CR-502 (FB), 2020 WL 3577398 (E.D.N.Y. July 1, 2

" Id. (emphasis in original). We submit that a similarly situated defendant who, like Ms. Maxwell, had no prior criminal record, significant ties to the United States, and a demonstrated lack of intent to flee the country, as well as numerous, supportive co-signers, but who did 20 EFTA00083347 Case 1:20-cr-0033

Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 21 of 26 France and the United Kingdom.13 Notably, two weeks ago, this Court recognized in United States v. Abdellatif El Mokadem, No. 19-CR-646 (AN), 2020 WL 3440515 (S.D.N.Y. June 23, 2020) that "concerns regarding risk of flight are mitigated by the

S.D.N.Y. Mar. 31, 2020) 8, 9 United States v. Conway, No. 4-11-70756 MAG(DMR), 2011 WL 3421321 (N.D. Cal. Aug. 3,2011) 10, 18 United States v. Crowell, No. 06-CR-291E(F), 2006 WL 3541736 (W.D.N.Y. Dec. 7, 2006) 11 United States v. Deutsch, No. 18-CR-502 (FB), 2020 WL 3577398 (E.D.N.Y. July 1, 2

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

f production—not a burden of persuasion—to rebut that presumption by coming forward with evidence that [she] does not pose . . . a risk of flight." See United States v. English, 629 F.3d 311, 319 (2d Cir. 2011) (quotation omitted). This rebuttable presumption can be readily satisfied, United States v. Conway, No

(S.D.N.Y. Mar. 31, 2020) 8, 9 United States v. Conway, No. 4-11-70756 MAG(DMR), 2011 WL 3421321 (N.D. Cal. Aug. 3, 2011) 10, 18 United States v. Crowell, No. 06-CR-291E(F), 2006 WL 3541736 (W.D.N.Y. Dec. 7, 2006) 1 I United States v. Deutsch, No. 18-CR-502 (FB), 2020 WL 3577398 (E.D.N.Y. July 1, 2

" Id. (emphasis in original). We submit that a similarly situated defendant who, like Ms. Maxwell, had no prior criminal record, significant ties to the United States, and a demonstrated lack of intent to flee the country, as well as numerous, supportive co-signers, but who did 20 EFTA01653647 Case 1:20-cr-0033

Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 21 of 26 France and the United Kingdom.13 Notably, two weeks ago, this Court recognized in United States v. Abdellatif El Mokadem, No. 19-CR-646 (AN), 2020 WL 3440515 (S.D.N.Y. June 23, 2020) that "concerns regarding risk of flight are mitigated by the

S.D.N.Y. Mar. 31, 2020) 8, 9 United States v. Conway, No. 4-11-70756 MAG(DMR), 2011 WL 3421321 (N.D. Cal. Aug. 3,2011) 10, 18 United States v. Crowell, No. 06-CR-291E(F), 2006 WL 3541736 (W.D.N.Y. Dec. 7, 2006) 11 United States v. Deutsch, No. 18-CR-502 (FB), 2020 WL 3577398 (E.D.N.Y. July 1, 2

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

S.D.N.Y. Mar. 31, 2020) 8, 9 United States v. Conway, No. 4-11-70756 MAG(DMR), 2011 WL 3421321 (N.D. Cal. Aug. 3,2011) 10, 18 United States v. Crowell, No. 06-CR-29IE(F), 2006 WL 3541736 (W.D.N.Y. Dec. 7, 2006) 11 United States v Deutsch, No. 18-CR-502 (FB), 2020 WL 3577398 (E.D.N.Y. July 1, 20

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