Epstein Secrets

their national legislation (France, Lebanon, Chili, Qatar, Slovenia). By contrast, many States - in particular, Common law jurisdictions, including the United Kingdom, Australia, and the USA, extradite their own citizens. 66. Thus, there is no uniform rule regarding the extradition of nationals under internationa

991. I am currently incarcerated at the Metropolitan Detention Center in Brooklyn, New York. 2. I have reviewed with my counsel, Mark S. Cohen and Christian R. Everdell of Cohen & Gresser, LLP, the charges contained in the superseding indictment in the above- captioned case (the "Indictment"). In addition, I have be

their national legislation (France, Lebanon, Chili, Qatar, Slovenia). By contrast, many States - in particular, Common law jurisdictions, including the United Kingdom, Australia, and the USA, extradite their own citizens. 66. Thus, there is no uniform rule regarding the extradition of nationals under internationa

991. I am currently incarcerated at the Metropolitan Detention Center in Brooklyn, New York. 2. I have reviewed with my counsel, Mark S. Cohen and Christian R. Everdell of Cohen & Gresser, LLP, the charges contained in the superseding indictment in the above- captioned case (the "Indictment"). In addition, I have be

ingdom and the United States of America are governed by an extradition treaty signed on 31 March 20033, which is given effect in the domestic law of the United Kingdom.' by the 2003 Ace. Overview of the extradition process 4. The United States of America has been designated as a `Part 2 territory' (also referred t

991. I am currently incarcerated at the Metropolitan Detention Center in Brooklyn, New York. 2. I have reviewed with my counsel, Mark S. Cohen and Christian R. Everdell of Cohen & Gresser, LLP, the charges contained in the superseding indictment in the above- captioned case (the "Indictment"). In addition, I have be

nt made the following point in support of its motion to detain the defendant: "The government has spoken with the Department of Justice attaches in the United Kingdom and France. With respect to France, we have been informed that France will not extradite a French citizen to the United States as a matter of law,

991. I am currently incarcerated at the Metropolitan Detention Center in Brooklyn, New York. 2. I have reviewed with my counsel, Mark S. Cohen and Christian R. Everdell of Cohen & Gresser, LLP, the charges contained in the superseding indictment in the above- captioned case (the "Indictment"). In addition, I have be

GHISLAINE MAXWELL, Defendant. 20 Cr. 330 (MN) REPLY N1EMOR kNDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.

e Government's Assertion that Ms. Maxwell Is "Adept" at Hiding and Therefore a Flight Risk Is Specious 7 D. Refusal of Extradition from France or the United Kingdom Is Highly Unlikely 8 E. The Recent COVID Surge at MDC Further Justifies Bail 10 CONCLUSION 10 i EFTA00015978 --- PAGE BREAK --- TABLE OF

HISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East

5 C. The Government's Assertion that Ms. Maxwell Is "Adept" at Hiding and Therefore a Flight Risk Is Specious 7 D. Extradition from France or the United Kingdom Is Highly Unlikely 8 E. The Recent COVID Surge at MDC Further Justifies Bail 10 CONCLUSION 10 i EFTA00016770 --- PAGE BREAK --- TABLE OF

Cr. 330 (MN) MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S THIRD MOTION FOR RELEASE ON BAIL Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim Christian R. Everdell COHEN & GRESSER LLP MEN Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Attorneys for Ghislaine Maxwell EFTA00018709 --

rs that the Court deemed insufficient and should satisfy any concerns the Court may have that Ms. Maxwell may try to seek a safe haven in France or the United Kingdom. (See id. at 11-13). As a non-citizen, Ms. Maxwell will not be able to avail herself of any protections against extradition that may apply to 2 EF

HISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.

5 C. The Government's Assertion that Ms. Maxwell Is "Adept" at Hiding and Therefore a Flight Risk Is Specious 7 D. Extradition from France or the United Kingdom Is Highly Unlikely 8 E. The Recent COVID Surge at MDC Further Justifies Bail 10 CONCLUSION 10 EFTA00019292 --- PAGE BREAK --- TABLE OF AUT

PPORT OF HER THIRD MOTION FOR RAII Bobbi C. Sternheim Law Offices of Bobbi C. Stemhcim 33 West 19th Street - 4th Floor New York NY 10011 Phone: Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York NY 10022 Phone:_ Jeffrey S. Pagliuca Laura A. Mcnninger HADDON, MORGAN & FOREMAN P.0 150 East 1

PAGE BREAK --- WILLIAM JULIE AVOCAT A LA COUR - ATTORNEY AT LAW extradition and other removals", ECtHR 12 April 2012, Babar Ahmad and Others v. the United Kingdom, no. 24027/07, §168). 23. France has no difficulty with deporting individuals who have lost French nationality by application of Article 25 of the