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N SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Jeff
eover, this should not be a bar to granting bail. The proposed conditions ensure her presence at home in plain sight of monitored, and under strict Pretrial supervision. D. Ms. Maxwell Has Waived Her Extradition Rights and Could Not Seek Refuge in the United Kingdom or France At the initial hearing, t
N SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Jeff
eover, this should not be a bar to granting bail. The proposed conditions ensure her presence at home in plain sight of monitored, and under strict Pretrial supervision. D. Ms. Maxwell Has Waived Her Extradition Rights and Could Not Seek Refuge in the United Kingdom or France At the initial hearing, t
N SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP New
g bail. The proposed conditions ensure her presence at home in plain sight of her sister (and the security guards), GPS- monitored, and under strict Pretrial supervision. D. Ms. Maxwell Has Waived Her Extradition Rights and Could Not Seek Refuge in the United Kingdom or France At the initial hearing, t
013 WL 3802012 (S.D.N.Y. July 19, 2013) 16, 19 United States v. Cirillo, No. 99-1514, 1999 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
to granting bail. The proposed conditions ensure her presence at home in plain sight of (and the security guards), GPS- monitored, and under strict Pretrial supervision. D. Ms. Maxwell Has Waived Her Extradition Rights and Could Not Seek Refuge in the United Kingdom or France At the initial hearing, t
address the merits, the government attempts to dismiss the significance of Ms. Maxwell's relationship with her spouse, noting that Ms. Maxwell told Pretrial Services that she was in the process of getting a divorce and that her spouse did not step forward as a co-signer at the initial bail hearing. (Id.
Page: EFTA00016776 →auent-iean-luc-brunel-in-ieffrev-epstein-inquiry. 10 EFTA00016782 --- PAGE BREAK --- Dated: December 18, 2020 Respectfully submitted, is/Marks Cohen Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HA
Page: EFTA00016783 →TO THE GOVERNMENT'S MOTION FOR DETENTION Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800
Page: EFTA00018515 →continue to need security guards to protect her upon release. Under the circumstances, if the Court requires it, the security guards could report to Pretrial Services.16 10 In United States v. Houston!, 932 F.3d 79 (2d Cir. 2019), the Second Circuit curtailed the circumstances under which a court can gra
Page: EFTA00018538 →N SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800
Page: EFTA00019291 →address the merits, the government attempts to dismiss the significance of Ms. Maxwell's relationship with her spouse, noting that Ms. Maxwell told Pretrial Services that she was in the process of getting a divorce and that her spouse did not step forward as a co-signer at the initial bail hearing. (Id.
Page: EFTA00019298 →Entities connected to both Michael Cohen and Pretrial

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSONLeon Black
PERSONJeffrey Pagliuca
PERSON
Marc Rich
PERSON
United States
LOCATION
Denver
LOCATION
George W. Bush
PERSON
Department of Justice
ORGANIZATIONLaura Menninger
PERSON
Joe Biden
PERSONSouthern District
LOCATIONCohen & Gresser LLP
ORGANIZATION
Stephen Hawking
PERSONMartin Weinberg
PERSON
Bill Clinton
PERSON
Barack Obama
PERSON
Eric Trump
PERSON
Virginia Giuffre
PERSON