FD-302 (Rev. 5-8-10)
FD-302 (Rev. 5-8-10) -1 of 3- Cil;EIMA: 71 RD UNCLASSIFIEDUF0U0 FEDERAL BUREAU OF INVESTIGATION Macacmry 07/02/2020 Martin Anthony Jackson, date of birth (DOB) , of II cell phone , email address was interviewed at . After being advised of the identity of the interviewing Agent and the nature of the interview, Jackson provided the following information: Jackson, a former member of the British Army (retired /C , had been contacted by Matthew Hellyer whom Jackson served in the British Army with about a body guard type position guarding Ghislaine Maxwell recently. Hellyer had been retained by Maxwell's brother (Kevin) to arrange for former British Army members (from his former unit) to provide a security service for Maxwell at her residence in Bradford, NH. Jackson would contact Matthew Hellyer, who is residing in Poole, United Kingdom, at telephone related to the Maxwell assignment. Jackson is being paid $350.00/day by Hellyer, who makes the deposits directly into Ja
Summary
FD-302 (Rev. 5-8-10) -1 of 3- Cil;EIMA: 71 RD UNCLASSIFIEDUF0U0 FEDERAL BUREAU OF INVESTIGATION Macacmry 07/02/2020 Martin Anthony Jackson, date of birth (DOB) , of II cell phone , email address was interviewed at . After being advised of the identity of the interviewing Agent and the nature of the interview, Jackson provided the following information: Jackson, a former member of the British Army (retired /C , had been contacted by Matthew Hellyer whom Jackson served in the British Army with about a body guard type position guarding Ghislaine Maxwell recently. Hellyer had been retained by Maxwell's brother (Kevin) to arrange for former British Army members (from his former unit) to provide a security service for Maxwell at her residence in Bradford, NH. Jackson would contact Matthew Hellyer, who is residing in Poole, United Kingdom, at telephone related to the Maxwell assignment. Jackson is being paid $350.00/day by Hellyer, who makes the deposits directly into Ja
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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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