Exhibit E
Exhibit E EFTA00065588 Kevin Maxwell The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, NY 10007 Your Honor November 23rd 2020 This statement is in support of Ghislaine Maxwell's request for bail and her character. My name is Kevin Maxwell. I am an entrepreneur working in the real estate development sector specialising in Purpose Built Student Accommodation and social impact residential and infrastructure development. I write this letter in support of my younger sister Ghislaine Maxwell. We are the nearest in age in our surviving family of 7 siblings (I was born in February 1959 and Ghislaine in December 1961) and have always been close since childhood. We remain close and have been in communication by phone and videolink most weeks up until her arrest on July 2nd 2020; I have historically regularly visited her in the United States at least a couple of times a year and she has
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Exhibit E EFTA00065588 Kevin Maxwell The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, NY 10007 Your Honor November 23rd 2020 This statement is in support of Ghislaine Maxwell's request for bail and her character. My name is Kevin Maxwell. I am an entrepreneur working in the real estate development sector specialising in Purpose Built Student Accommodation and social impact residential and infrastructure development. I write this letter in support of my younger sister Ghislaine Maxwell. We are the nearest in age in our surviving family of 7 siblings (I was born in February 1959 and Ghislaine in December 1961) and have always been close since childhood. We remain close and have been in communication by phone and videolink most weeks up until her arrest on July 2nd 2020; I have historically regularly visited her in the United States at least a couple of times a year and she has
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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
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