Epstein Secrets

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

t has recently considered and granted pretrial release under that section. See United States v. Stephens, 447 F. Supp. 3d 63,66-68 (S.D.N.Y. 2020) (Nathan, J.); but see Alderete, 336 F.R.D. at 268. 11 EFTA00093420 CaszEsc'. 27-U412[9496W ntCldeanik4103013D2FH1800120612aagaSeid b2 16 Complicating matter

the police supply a suspect with a flow of information to help him calibrate his self- interest in deciding whether to speak or stand by his rights." Colorado v. Spring, 479 U.S. 564, 576-77 (1987) (internal quotation marks omitted); see also, e.g., id. at 577 (there is no requirement that law enforcement

ecise an identity between the character of the offenses!" United States v. Pizarro, No. 17 Cr. 151, 2018 WL 1737236, at *3 (S.D.N.Y. Apr. 10, 2018) (Nathan, J.) (quoting Werner, 620 138 EFTA00100105 F.2d at 929). Offenses may be joined "where the same evidence may be used to prove each count or if the c

the police supply a suspect with a flow of information to help him calibrate his self- interest in deciding whether to speak or stand by his rights." Colorado v. Spring, 479 U.S. 564, 576-77 (1987) (internal quotation marks omitted); see also, e.g., id. at 577 (there is no requirement that law enforcement

ecise an identity between the character of the offenses!" United States v. Pizarro, No. 17 Cr. 151, 2018 WL 1737236, at *3 (S.D.N.Y. Apr. 10, 2018) (Nathan, J.) (quoting Werner, 620 138 EFTA00077770 F.2d at 929). Offenses may be joined "where the same evidence may be used to prove each count or if the c

the police supply a suspect with a flow of information to help him calibrate his self- interest in deciding whether to speak or stand by his rights." Colorado v. Spring, 479 U.S. 564, 576-77 (1987) (internal quotation marks omitted); see also, e.g., id. at 577 (there is no requirement that law enforcement

ecise an identity between the character of the offenses!" United States v. Pizarro, No. 17 Cr. 151, 2018 WL 1737236, at *3 (S.D.N.Y. Apr. 10, 2018) (Nathan, J.) (quoting Werner, 620 138 EFTA00039585 F.2d at 929). Offenses may be joined "where the same evidence may be used to prove each count or if the c

the police supply a suspect with a flow of information to help him calibrate his self- interest in deciding whether to speak or stand by his rights." Colorado v. Spring, 479 U.S. 564, 576-77 (1987) (internal quotation marks omitted); see also, e.g., id. at 577 (there is no requirement that law enforcement

ecise an identity between the character of the offenses!" United States v. Pizarro, No. 17 Cr. 151, 2018 WL 1737236, at *3 (S.D.N.Y. Apr. 10, 2018) (Nathan, J.) (quoting Werner, 620 F.2d at 929). Offenses may be joined "where the same evidence may be used to prove each count or if the counts have a suffici

the police supply a suspect with a flow of information to help him calibrate his self- interest in deciding whether to speak or stand by his rights." Colorado v. Spring, 479 U.S. 564, 576-77 (1987) (internal quotation marks omitted); see also, e.g., id. at 577 (there is no requirement that law enforcement

cise an identity between the character of the offenses."' United States v. Pizarro, No. 17 Cr. 151, 2018 WL 1737236, at *3 (S.D.N.Y. Apr. 10, 2018) (Nathan, J.) (quoting Werner, 620 138 EFTA00103163 F.2d at 929). Offenses may be joined "where the same evidence may be used to prove each count or if the c