The document is a court filing arguing for Ghislaine Maxwell's bail, citing her strong ties to the U...
The document is a court filing arguing for Ghislaine Maxwell's bail, citing her strong ties to the United States, including her spouse and friends, and criticizing the government's handling of the case and its comparison to the Epstein case. The defense argues that new information has come to light since the initial bail hearing, including Maxwell's spouse coming forward as a co-signor. The government is accused of not scrutinizing the accusers' accounts seriously.
Summary
The document is a court filing arguing for Ghislaine Maxwell's bail, citing her strong ties to the United States, including her spouse and friends, and criticizing the government's handling of the case and its comparison to the Epstein case. The defense argues that new information has come to light since the initial bail hearing, including Maxwell's spouse coming forward as a co-signor. The government is accused of not scrutinizing the accusers' accounts seriously.
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UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES 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. Denver, CO 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim New York, NY 10011 Phone: Attorneys for Ghislaine Maxwell EFTA00094289 TABLE OF CONTENTS Page PRELIMINARY STATEMENT 1 ARGUMENT 7 I. Reconsideration of the Court's Bail Decision is Appropriate Under 18 U.S.C. § 3142(O 7 II. Ms. Maxwell Should Be Granted Bail Under the Proposed Strict Bail Conditions 10 A. Ms. Maxwell Has Deep Family Ties to the United States and Numerous Sureties to Support Her Bond 10 1. Ms. Maxwell is Devoted to Her Spouse and Stepchildren and Would Never Destroy Her Family By Leaving th
court filing or affidavit: DOJ-OGR-00020040
The document describes the intense media attention and violent threats directed at Ghislaine Maxwell, forcing her to take drastic steps to protect herself, including leaving her home. It includes examples of threatening posts and statements from Maxwell's spouse about the impact of media intrusion. The situation is likened to other instances where conspiracy theories led to violence.
Exhibit 0
Exhibit 0 EFTA00065551 GHISLAINE MAXWELL FINANCIAL CONDITION REPORT: 2015 - 2020 INDEPENDENT REPORT & COMMENTARY PREPARED BY MACALVINS LIMITED CHARTERED ACCOUNTANTS FOR COHEN & GRESSER LLP Wage EFTA00065552 GHISLAINE MAXWELL FINANCIAL CONDITION REPORT 2015 - 2020 Table of Contents Independent Accountants' Commentary Statement of Financial Condition Appendices 3 9 2IPage EFTA00065553 Independent Accountants' Commentary Cohen & Gresser LLP 1. In accordance with our engagement of 10 August 2020, we have prepared a summary of the financial condition of Ghislaine Maxwell based on the following information (i) Copies of her US tax returns filed in the years 2015 to 2020' (ii) Documentation provided by Ghislaine Maxwell's office and her spouse including bank statements and financial correspondence relating to bank accounts, pension fund, and investments2 (iii) Documentation provided by the United States Attorney's Office for the Southern District of New York u
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S THIRD MOTION FOR RELEASE ON BAIL Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Attorneys for Ghislaine Maxwell EFTA00090990 INTRODUCTION Ghislaine Maxwell respectfully submits this Memorandum in Support of her Third Motion for Release on Bail. As Ms. Maxwell has stated on numerous occasions and reaffirms here: she has no intention or desire to leave this country. She is an American citizen, has lived in United States for 30 years, has strong family ties and the support of friends and family residing in this country. She wants nothing more than to remain in the United States under whatever conditions the Court deems necessary so that she can effectively prepare fo
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S THIRD MOTION FOR RELEASE ON BAIL Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 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, Colorado 80203 Phone: Attorneys for Ghislaine Maxwell EFTA00083701 INTRODUCTION Ghislaine Maxwell respectfully submits this Memorandum in Support of her Third Motion for Release on Bail. As Ms. Maxwell has stated on numerous occasions and reaffirms here: she has no intention or desire to leave this country. She is an American citizen, has lived in United States for 30 years, has strong family ties and the support of friends and family residing in this
Exhibit 0
Exhibit 0 EFTA00088971 GHISLAINE MAXWELL FINANCIAL CONDITION REPORT: 2015 - 2020 INDEPENDENT REPORT & COMMENTARY PREPARED BY MACALVINS LIMITED CHARTERED ACCOUNTANTS FOR COHEN & GRESSER LLP Wage EFTA00088972 GHISLAINE MAXWELL FINANCIAL CONDITION REPORT 2015 - 2020 Table of Contents Independent Accountants' Commentary Statement of Financial Condition Appendices 3 9 2IPage EFTA00088973 Independent Accountants' Commentary Cohen & Gresser LLP 1. In accordance with our engagement of 10 August 2020, we have prepared a summary of the financial condition of Ghislaine Maxwell based on the following information (i) Copies of her US tax returns filed in the years 2015 to 2020' (ii) Documentation provided by Ghislaine Maxwell's office and her spouse including bank statements and financial correspondence relating to bank accounts, pension fund, and investments2 (iii) Documentation provided by the United States Attorney's Office for the Southern District of New York u
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