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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
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
he could face up to 35 years in prison if she is convicted." Maxwell, 58, "has been held without bail since her July 2 arrest at her million-dollar New Hampshire estate, where prosecutors say she refused to open the door for FBI agents, who busted through to find that she had retreated to an interior room. H
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
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
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 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
Case 1:20-cr-00330-AJN Document 38 Filed 08/10/20 Page 1 of 6 COHEN & GRESSER LLP Mark S. Cohen +1 (212) 957-7600 mcohen(cticohengresscr.com Christian R. Everdell +1 (212) 957-7600 [email protected] August 10, 2020 VIA ECF The H
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
Case 1:20-cr-00330-AJN Document 38 Filed 08/10/20 Page 1 of 6 COHEN & GRESSER LLP Mark S. Cohen +1 (212) 957-7600 mcohen(cticohengresscr.com Christian R. Everdell +1 (212) 957-7600 [email protected] August 10, 2020 VIA ECF The H
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
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
July 03, 2020 11:42 AM To: Christian Everdell• Cc: Subject: RE: SDNY indictment Chris and Mark, ; Mark S. Cohen We are working with the USMS in New Hampshire to add you both to the list of attorneys who may contact your client while she is detained there. To that end, the NH USMS have asked for the best p
. My cell is From: ) [mailto Sent: Friday, July 03, 2020 11:42 AM To: Christian Everdell• Cc: Subject: RE: SDNY indictment Chris and Mark, ; Mark S. Cohen We are working with the USMS in New Hampshire to add you both to the list of attorneys who may contact your client while she is detained there. To
July 03, 2020 11:42 AM To: Christian Everdell: Cc: Subject: RE: SDNY indictment Chris and Mark, ; Mark S. Cohen We are working with the USMS in New Hampshire to add you both to the list of attorneys who may contact your client while she is detained there. To that end, the NH USMS have asked for the best p
From: Christian Everdell Sent: Sunday, July 5, 2020 5:49 PM To: Cc: Subject: RE: SDNY indictment >; Mark S. Cohen Thanks, We are planning to make a bail submission on Thursday, subject to being able to communicate with our client. So we will need your help to
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
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 &
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
Page: EFTA00018575 →asons set forth above, we respectfully 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 New York, New York 10022 cc: All counsel of record (via ECF) EFTA00018577
Page: EFTA00018577 →Entities connected to both New Hampshire and Mark S. Cohen

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSON
Michael Cohen
PERSON
Prince Andrew
PERSON
United States
LOCATIONJeffrey Pagliuca
PERSON
Alison J. Nathan
PERSON
Donald Trump
PERSON
Department of Justice
ORGANIZATION
George W. Bush
PERSON
Christian Everdell
PERSON
Bill Clinton
PERSONLeon Black
PERSON
Joe Biden
PERSONSouthern District
LOCATION
Virginia Giuffre
PERSONCohen & Gresser LLP
ORGANIZATIONthe Southern District
LOCATIONLaura Menninger
PERSON
Michael Jackson
PERSON