Federal Court Filing: Reply Memorandum Of Ghislaine Maxwell (EFTA00104533)

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, v. 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER THIRD MOTION FOR RAIL Bobbi C. Sternheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York NY 10011 Phone: 1IMI Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New Y Phone Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.0 150 East 10th Avenue Denve Attorneys for Ghislaine Maxwell EFTA00104533 Preliminary Statement The issue before the Court, as it has been since Ms. Maxwell's first bail application, is whether conditions exist that can reasonably assure Ms. Maxwell's appearance at trial. On her third application (the "Third Bail Motion") (Dkt.160), Ms. Maxwell has put before the Court significant enhancements to the already extraordinary bail package previously presented to the Court in her renewed application fo