Epstein Secrets

xwell was not "changing locations on multiple occasions" as if she were a fugitive from justice. (Tr. 87). After Ms. Maxwell moved into the house in New Hampshire in December 2019, she remained there continuously for approximately seven months until her arrest. (See Ex. B) ("[S]he was finally able to locate a

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 of Bobbi C. Stemheim Attorneys for Ghislaine

xwell was not "changing locations on multiple occasions" as if she were a fugitive from justice. (Tr. 87). After Ms. Maxwell moved into the house in New Hampshire in December 2019, she remained there continuously for approximately seven months until her arrest. (See Ex. B) ("[S]he was finally able to locate a

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 of Bobbi C. Stemheim Attorneys for Ghislaine

Maxwell has been confined alone in an area outside of the general population for the entire 36- day period (40 days if we include her confinement in New Hampshire), which is over three weeks longer than the 14-day quarantine period required for all new arrivals to the MDC under current COVID-19 protocols, and

submit that the Court should grant Ms. Maxwell's motion. Respectfully submitted, /s/ Christian R. Everdell Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 cc: All counsel of record (via ECF) EFTA00077105

Maxwell has been confined alone in an area outside of the general population for the entire 36- day period (40 days if we include her confinement in New Hampshire), which is over three weeks longer than the 14-day quarantine period required for all new arrivals to the MDC under current COVID-19 protocols, and

submit that the Court should grant Ms. Maxwell's motion. Respectfully submitted, /s/ Christian R. Everdell Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue, 21st Floor New York, New York 10022 (212) 957-7600 cc: All counsel of record (via ECF) EFTA00085092

xwell was not "changing locations on multiple occasions" as if she were a fugitive from justice. (Tr. 87). After Ms. Maxwell moved into the house in New Hampshire in December 2019, she remained there continuously for approximately seven months until her arrest. (See Ex. B) ("[S]he was finally able to locate a

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. Denver, CO 80203 Phone: Bobbi C. Stemheim Law

ntly it appears that she spent the last year making concerted efforts to conceal her whereabouts whilst moving around New England, most recently to New Hampshire, which I will discuss momentarily with respect to that particular THE COURT: : -- property. THE COURT: there is one assertion in the defense pa

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 & FOREMAN P.C. 150 East 10th Avenue Denver,

! From: Sent: Friday, July 3, 202012:42 PM To: Subject: RE: Ghislaine Maxwell custody Terrific, thanks very much. Both attorneys are partners at Cohen & Gresser LLP. Chris Everdell's number i Mark Cohen's number is Thanks again, From: Sent: Friday, July 3, 2020 11:39 AM To: Subject: RE: Ghislaine Maxwell cu

to the press regarding this matter or our SOP regarding this inmate. Supervisory Deputy United States Marshal District of New Hampshire Concord, New Hampshire office EFTA00024545 --- PAGE BREAK --- This e-mail is property of U.S. Marshals Service. It is intended only for the person or entity to which i

From: Sent: Friday, July 3, 2020 12:42 PM To: Subject: RE: Ghislaine Maxwell custody Terrific, thanks very much. Both attorneys are partners at Cohen & Gresser LLP. Chris Everdell's number i Mark Cohen's number Thanks again, wrote: EFTA00014916 --- PAGE BREAK --- From: Sent: Friday, July 3, 2020 11:39 A

to the press regarding this matter or our SOP regarding this inmate. Supervisory Deputy United States Marshal District of New Hampshire Concord, New Hampshire office This e-mail is property of U.S. Marshals Service. It is intended only for the person or entity to which it is addressed and may contain inf