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. Maxwell was the subject of over 6,500 national media articles. That exceeds the number of articles that mentioned such high-profile defendants as Harvey Weinstein, Bill Cosby, Joaquin "El Chapo" Guzman Loera, and Keith Raniere in the 90-day period following their arrests, combined. The media coverage has ruth
day period immediately following her arrest, Ms. Maxwell was mentioned in more national media articles than in the analogous 90-day periods for Mr. Weinstein, Mr. Cosby, Mr. Guzman Loera, and Mr. Raniere combined. ALL U.S. MEDIA COVERAGE COMPARISON (90 DAYS OF ARREST) 7.000 6.000 5.000 V t y 4,000
es that mentioned such high-profile defendants as Harvey Weinstein, Bill Cosby, Joaquin "El Chapo" Guzman
ES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Bobbi C. Stemheim Law Offices o
"known for representing Hollywood producer Harvey Weinstein against sexual-assault accusations, and companie
irm is "known for representing Hollywood producer Harvey Weinstein against sexual-assault accusations, an
w firm founded by trial lawyer David Boies, was approved for up to $10 million." Reuters says the firm is "known for representing Hollywood producer Harvey Weinstein against sexual-assault accusations, and companies ranging from Oracle to Theranos." Politico (7/6, Warmbrodt, 4.29M) reports that "as of Tuesday, t
l decide to appear by video from the MDC, Thursday or next Tuesday are the soonest spots available." The Post adds, "Hours later, Maxwell's attorney Mark S. Cohen said in a court filing that she `has agreed to waive her physical presence' for her court appearance. He asked for Nathan to schedule the case for
Judge, Expressing Skepticism, Upends $25 Million Harvey Weinstein Settlement Three Marines, Now Focus of Russian B
Expressing Skepticism, Upends $25 Million Harvey Weinstein Settlement Three Marines, Now Focus of Russian B
Judge, Expressing Skepticism, Upends $25 Million Harvey Weinstein Settlement Three Marines, Now Focus of
ere prosecutors say she refused to open the door for FBI agents, who busted through to find that she had retreated to an interior room. Her lawyer, Mark S. Cohen, told the judge that Maxwell was in her pajamas and had been told that security protocol called for her to retreat to her room if there was any dist
. Maxwell was the subject of over 6,500 national media articles. That exceeds the number of articles that mentioned such high-profile defendants as Harvey Weinstein, Bill Cosby, Joaquin "El Chapo" Guzman Loera, and Keith Raniere in the 90-day period following their arrests, combined. The media coverage has ruth
day period immediately following her arrest, Ms. Maxwell was mentioned in more national media articles than in the analogous 90-day periods for Mr. Weinstein, Mr. Cosby, Mr. Guzman Loera, and Mr. Raniere combined. ALL U.S. MEDIA COVERAGE COMPARISON (90 DAYS OF ARREST) 7.000 6.000 5.000 V t y 4,000
es that mentioned such high-profile defendants as Harvey Weinstein, Bill Cosby, Joaquin "El Chapo" Guzman
ES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Bobbi C. Stemheim Law Offices o
. Maxwell was the subject of over 6,500 national media articles. That exceeds the number of articles that mentioned such high-profile defendants as Harvey Weinstein, Bill Cosby, Joaquin "El Chapo" Guzman Loera, and Keith Raniere in the 90-day period following their arrests, combined. The media coverage has ruth
day period immediately following her arrest, Ms. Maxwell was mentioned in more national media articles than in the analogous 90-day periods for Mr. Weinstein, Mr. Cosby, Mr. Guzman Loera, and Mr. Raniere combined. ALL U.S. MEDIA COVERAGE COMPARISON (90 DAYS OF ARREST) 7.000 6.000 5.000 5. a 4.003
es that mentioned such high-profile defendants as Harvey Weinstein, Bill Cosby, Joaquin "El Chapo" Guzman
ES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER RENEWED MOTION FOR BAIL Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Denv
es that mentioned such high-profile defendants as Harvey Weinstein, Bill Cosby, Joaquin "El Chapo" Guzman
. Maxwell was the subject of over 6,500 national media articles. That exceeds the number of articles that mentioned such high-profile defendants as Harvey Weinstein, Bill Cosby, Joaquin "El Chapo" Guzman Loera, and Keith Raniere in the 90-day period following their arrests, combined. The media coverage has ruth
day period immediately following her arrest, Ms. Maxwell was mentioned in more national media articles than in the analogous 90-day periods for Mr. Weinstein, Mr. Cosby, Mr. Guzman Loera, and Mr. Raniere combined. ALL U.S. MEDIA COVERAGE COMPARISON (90 DAYS OF ARREST) 7.000 6.000 6000 6.000 6 too°
ES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) 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 &
or more serious offenses, many of whom have foreign ties, are routinely granted bail so that they can effectively prepare for trial. Bernie Madoff. Harvey Weinstein. Bill Cosby. John Gotti. Marc Dreier. Dominique Strauss- Kahn. Ali Sadr. Adnan Khashoggi. Mahender Sabhnani. The list goes on and on. In each case,
ctively prepare for trial. Bernie Madoff. Harvey Weinstein. Bill Cosby. John Gotti. Marc Dreier. Dominique S
can effectively prepare for trial. Bernie Madoff. Harvey Weinstein. Bill Cosby. John Gotti. Marc Dreier.
LAINE MAXWELL, Defendant. • • • • x 20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL JN OPPOSITION TO THE GOVERNMENT'S MOTION FOR DETENTION Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca (pro hoc vice admission pending) Lau
States v. Gebbie, 294 F.3d 540 (3d Cir. 2002) 24, 25 United States v. Gonzalez, 93 F. App'x 268 (2d Cir. 2004) 14, 22, 27, 29 United States v. Harvey, 791 F.2d 294 (4th Cir. 1986) 24 United States v. Laskow, 688 F. Supp. 851 (E.D.N.Y.), aff'd, 867 F.2d 1425 (2d Cir. 1988) 21 United States v.
20 Cr. 330 (AJN) MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS SUPERSEDING INDICTMENT FOR BREACH OF NON-PROSECUTION AGREEMENT Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Bobbi C. Stemheim Law Offices o
States v. Gebbie, 294 F.3d 540 (3d Cir. 2002) 24, 25 United States v. Gonzalez, 93 F. App'x 268 (2d Cir. 2004) 14, 22, 27, 29 United States v. Harvey, 791 F.2d 294 (4th Cir. 1986) 24 United States v. Laskow, 688 F. Supp. 851 (E.D.N.Y.), aff'd, 867 F.2d 1425 (2d Cir. 1988) 21 United States v.
that Ms. Maxwell be permitted to take discovery in aid of such I hearing. Dated: January 25, 2021 New York, New York Respectfully submitted, /s/ Mark S. Cohen Attorneys for Ghislaine Maxwell 32 EFTA00099388 CERTIFICATE OF SERVICE I hereby certify that on January 25, 2021, I served by email, pursuant R
Entities connected to both Harvey Weinstein and Mark S. Cohen

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Michael Cohen
PERSON
Donald Trump
PERSON
George W. Bush
PERSON
United States
LOCATIONLeon Black
PERSON
Bill Clinton
PERSON
Stephen Hawking
PERSON
Bradley Edwards
PERSON
Julie K. Brown
PERSON
Department of Justice
ORGANIZATION
Joe Biden
PERSON
Eric Trump
PERSONthe Southern District
LOCATION
Scarlett Johansson
PERSON
John F. Kennedy
PERSONJeffrey Pagliuca
PERSON
Virginia Giuffre
PERSON