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venue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: 303-831-7364 Attorneys for Ghislaine Maxwell EFTA00083712 INTRODUCTION Ghislaine Maxwell respectfully submits this Memorandum in S
on of a former federal District Court judge eliminates any concern that such funds could be used to violate the terms of release. IL Ms. Maxwell's Pretrial Motions Raise Substantial Legal and Factual Issues That Could Result in Dismissal of Some or All of the Charges Against Her In addition to the new conditions proposed above, the n
800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: Attorneys for Ghislaine Maxwell EFTA00083701 INTRODUCTION Ghislaine Maxwell respectfully submits this Memorandum in Support of her
on of a former federal District Court judge eliminates any concern that such funds could be used to violate the terms of release. IL Ms. Maxwell's Pretrial Motions Raise Substantial Legal and Factual Issues That Could Result in Dismissal of Some or All of the Charges Against Her In addition to the new conditions proposed above, the n
venue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: 303-831-7364 Attorneys for Ghislaine Maxwell EFTA00083790 INTRODUCTION Ghislaine Maxwell respectfully submits this Memorandum in S
on of a former federal District Court judge eliminates any concern that such funds could be used to violate the terms of release. IL Ms. Maxwell's Pretrial Motions Raise Substantial Legal and Factual Issues That Could Result in Dismissal of Some or All of the Charges Against Her In addition to the new conditions proposed above, the n
800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: Attorneys for Ghislaine Maxwell EFTA00093352 a2k3w22eAD0olTaaciAers 113ctiMith1/202 1 ,Faiii%223ft 4 ,740123219 INTRODUCTION Ghis
on of a former federal District Court judge eliminates any concern that such funds could be used to violate the terms of release. H. Ms. Maxwell's Pretrial Motions Raise Substantial Legal and Factual Issues That Could Result in Dismissal of Some or All of the Charges Against Her In addition to the new conditions proposed above, the n
Entities connected to both Colorado and Pretrial Motions Raise Substantial Legal

Jeffrey Epstein
PERSON
Denver
LOCATION
Ghislaine Maxwell
PERSON
Michael Cohen
PERSON
United States
LOCATIONJeffrey Pagliuca
PERSON
John F. Kennedy
PERSON
United Kingdom
LOCATION
Richard Kahn
PERSONthe Northern District
LOCATIONMORGAN & FOREMAN
ORGANIZATIONCohen & Gresser LLP
ORGANIZATIONBobbi C. Sternheim
PERSONR. Everdell
PERSONPretrial Services
ORGANIZATION
Dominique Strauss-Kahn
PERSONPetrov
PERSONWilliam S. Duffey
PERSONStrauss-Kahn's
PERSONThe Proposed Additional Bail Conditions
ORGANIZATION