EFTA00018515.pdf

"UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. 20 Cr. 330 (AJN)"

"Mark S. Cohen... Attorneys for Ghislaine Maxwell"

"Christian R. Everdell... Attorneys for Ghislaine Maxwell"

"Jeffrey S. Pagliuca... Attorneys for Ghislaine Maxwell"

"Laura A. Menninger... Attorneys for Ghislaine Maxwell"

"Ms. Maxwell graduated from Oxford University."

"she has lived in the United States since 1991"

"In July 2019, Epstein was indicted for offenses relating to sexual misconduct"

"The Court should exercise its discretion to grant bail to Ms. Maxwell"

"She moved to the United States in 1991, and has lived in this country ever since that time."

"as well as a citizen of the United States"

"is a citizen of the United Kingdom and France"

"is a citizen of the United Kingdom and France"

"Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 14 of 26 ... The government bears a dual burden in seeking pre-trial detention."

"on July 7, 2019, the day after Epstein's arrest, Ms. Maxwell reached out to the prosecutors in the Southern District of New York, through counsel"

"She has lived in this country for almost 30 years and became a naturalized U.S. citizen in 2002."

"Two of her sisters, who have agreed to co-sign her bond, live in the United States... Ms. Maxwell is very close with her sisters"

"July 7, 2019, the day after Epstein's arrest"

"since 2015, and continuing through today, Ms. Maxwell has actively litigated several civil cases related to Epstein in the Southern District of New Yo"

"Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20"

"Jeffrey Epstein pal Ghislaine Maxwell"

"The Sun is offering a £10,000 reward for information on Jeffrey Epstein pal Ghislaine Maxwell"

"since Ms. Maxwell's arrest on July 2, 2020"

"Case 1:20-cr-00330-AJN Document 18... Ms. Maxwell has rebutted that presumption"

"Epstein's September 24, 2007 non-prosecution agreement with the Department of Justice"

"the conspiracy, enticement of minors, and transporting of minors charges are time-barred"

"the two perjury charges are subject to dismissal on several legal grounds"

"The bond is also to be secured by real property in the United Kingdom worth roughly $3.75 million."

"The government asserts that detention is warranted because of the potential for a long sentence in this case. (Gov. Mem. at 4-5.)"

"Ms. Maxwell respectfully requests that the Court order her release on bail pursuant to the conditions she has proposed."

"Attorneys for Ghislaine Maxwell... Mark S. Cohen"

"Attorneys for Ghislaine Maxwell... Christian R. Everdell"

"Attorneys for Ghislaine Maxwell... Jeffrey S. Pagliuca"

"Attorneys for Ghislaine Maxwell... Laura A. Menninger"

"Mark S. Cohen COHEN & GRESSER LLP"

"Jeffrey S. Pagliuca HADDON, MORGAN & FORMAN P.C."

"COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022"

"HADDON, MORGAN & FORMAN P.C. 150 East 10th Avenue Denver, Colorado 80203"

"For the foregoing reasons, Ms. Maxwell respectfully requests that the Court order her release... Respectfully submitted, /s/ Mark S. Cohen"

"graduated from Oxford University"

"Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 ... Ms. Maxwell has been housed since the Bureau of Prisons (BOP) transferred her there"

"Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 11 of 26"

"where Ms. Maxwell has been housed since the Bureau of Prisons (BOP) transferred her there on July 6, 2020"

"April 3, 2020 Report from the BOP regarding the Metropolitan Detention Center"

"The Court ordered us to confer with Ms. Maxwell about waiving her physical presence at the arraignment"

"We promptly emailed the MDC to request an urgent call, making specific reference to the Court's Order"

"the Court ordered us to confer with Ms. Maxwell about waiving her physical presence"

"concerns regarding risk of flight are mitigated by the ongoing [COVID-19] pandemic, which has understandably curtailed travel"

"she'd had no contact with Epstein for more than a decade... litigated civil cases arising from her supposed ties to Epstein"

"secured by real property in the United Kingdom worth over $3.75 million"