EFTA00094289.txt

"It describes the committed relationship between Ms. Maxwell and her spouse, who is a U.S citizen, and how they lived a quiet family life together with"

"Ms. Maxwell has now been detained for over 150 days in the equivalent of solitary confinement since she was indicted and arrested on July 2, 2020... a"

"Strict supervision by Pretrial Services."

"After Ms. Maxwell moved into the house in New Hampshire in December 2019, she remained there continuously for approximately seven months until her arr"

"only sure-fire means of ensuring the children's and my protection was for her to leave Massachusetts"

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

"Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP... Attorneys for Ghislaine Maxwell"

"A $22.5 million personal recognizance bond co-signed by Ms. Maxwell and her spouse, and secured by approximately $8 million in property and $500,000 i"

"A $1.5 million bond co-signed by her sisters Christine Maxwell and Isabel Maxwell... fully secured by Christine Maxwell's primary residence in Oakland"

"A $3.5 million bond co-signed by Ms. Maxwell's brother Kevin Maxwell, and his ex-wife, Pandora Maxwell"

"The $3.5 million sum represents virtually all of Pandora Maxwell's assets."

"Isabel Maxwell will serve as Ms. Maxwell's third-party custodian under 18 U.S.C. 3142(c)(1)(B)(i) and will live with Ms. Maxwell in a residence in New"

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

"Maxwell's home is in the United States with her spouse and his children and how deeply committed she is to her family"

"has agreed to co-sign Ms. Maxwell's $22.5 million bond and to post all three properties he owns"

"the security company that will provide security services to Ms. Maxwell... has agreed to post a $1 million bond"

"The 2015 tax return records the sale of a residential property in New York City for $15,075,000. The address of this property is 116 East 65th Street"

"116 E 65th LLC, an LLC established by Ms. Maxwell"

"proceeds of the sale were deposited at UBS in an account of 116 E 65th LLC"

"Mr. Faro reviewed the Macalvins report and the underlying documents and determined that it presents a complete and accurate summary"

"she is being treated in the MDC"

"Ms. Maxwell lived a quiet family life with her spouse and his two young children for almost four years until Epstein's arrest in July 2019"

"Ms. Maxwell's domestic life with her spouse and his two minor children in Massachusetts in the four years prior to her arrest."

"Ms. Maxwell is a citizen of France, a nation that does not appear to extradite its citizens"

"Ms. Maxwell has obtained substantial information and evidence that was not available to her at the time of her initial detention hearing."

"Attached to this submission are letters from Ms. Maxwell's spouse and from numerous close family members and friends, many of whom have agreed to serv"

"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"

"Bobbi C. Sternheim... Attorneys for Ghislaine Maxwell"

"Ms. Maxwell has spent the entirety of her detention—now over five months—in de facto solitary confinement... inside the MDC."

"the MDC warden"

"the government represented was the core of its case against Ms. Maxwell."

"submitted herewith is a report from David Perry (Perry Rep.), a U.K. barrister ... In Mr. Perry's opinion, it is highly unlikely that Ghislaine Maxwel"

"The accompanying report of William Julie (Julie Rep.) reviews the French extradition process as it would likely be applied to Ms. Maxwell."

"In 2011 and 2012, Mr. Perry was part of a select team appointed by the U.K. government to conduct a review of the United Kingdom's extradition arrange"

"the core of its case against Ms. Maxwell. ... The discovery contains no meaningful documentary corroboration"

"Ms. Maxwell married her spouse in 2016 and commenced filing joint U.S. tax returns"

"The sale of Ms. Maxwell's New York apartment coincided with her intention to move"

"her London residence worth approximately $3 million"

"the press rushed to substitute Ms. Maxwell for Epstein as the target of the scandal"

"other banks abruptly severed ties with him due to his connection to Ms. Maxwell following her arrest"

"documents related to the Giuffre v. Maxwell defamation case to which Ms. Maxwell was a party"

"The financial report, prepared by the accounting firm Macalvins Limited, provides an accounting of Ms. Maxwell's financial condition from 2015-2020"

"Matthew Hellyer, the head of the security company guarding Ms. Maxwell at the time of her arrest"

"Terramar Project, Inc., which is easily identifiable through a simple Google search as Ms. Maxwell's charity"

"Defense counsel also requested an opportunity to be heard in the event that the government was considering any charging decisions against Ms. Maxwell."

"Ms. Maxwell is devoted to Her Spouse and Stepchildren... A $22.5 million personal recognizance bond co-signed by Ms. Maxwell and her spouse"

"the uncorroborated testimony of a handful of witnesses about events that took place over 25 years ago."