171.pdf
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- pdf
- Source set
- house-oversight-doj
- Pages
- 18
- Text status
- Searchable text available
- OCR confidence
- 0.9270569321520167
Original source
Extracted text
Case 1:20-cr-00330-PAE Document171 Filed 03/23/21 Page1of18 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK a x UNITED STATES OF AMERICA, Vv. 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER THIRD MOTION FOR BAIL Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: 212-243-1100 Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C 150 East 10th Avenue Denver, CO 80203 Phone: 303-831-7364 Attorneys for Ghislaine Maxwell DOJ-OGR- 00002781
Case 1:20-cr-00330-PAE Document171 Filed 03/23/21 Page2of18 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 for bail (the “Second Bail Motion’) (Dkt. 97).! Together, these two motions present a unique and comprehensive bail package with the strictest of conditions known in any bail application: = $28.5 million in bonds (including a $1M bond co-signed by a security company); = $9.5 million in real property; =" $550,000 in cash; = Asset Monitoring by a retired federal district court judge; = Renunciation of British and French citizenship; = Irrevocable written waivers of the right to contest extradition; = Surrender of all travel documents; = Home confinement in New York City; = Electronic GPS monitoring; = I[n-residence third-party custodian;? ! Ms. Maxwell’s present motion (the “Third Bail Motion”) (Dkt.160) incorporates her Memorandum in Support of Her Renewed Motion for Bail and accompanying exhibits (Dkt. 97, including Attach…
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