Epstein Secrets

N SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Jeff

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

N SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Jeff

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

N SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP New

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

regarding pretrial submissions, including in limine motions and the like. With that, counsel, other matters to discuss regarding scheduling? Mr. Cohen? MR. COHEN: Not at this time, your Honor, not from the defense at this time. THE COURT: Thank you. : Nothing further from the government regardi

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

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

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