EFTA00015977.pdf

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Source set: data-set-8

Extracted text

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
v.
GHISLAINE MAXWELL,
Defendant.
20 Cr. 330 (MN)
REPLY N1EMOR kNDUM OF GHISLAINE MAXWELL
IN SUPPORT OF HER RENEWED MOTION FOR BAIL
Mark S. Cohen
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
Bobbi C. Stemheim
Law Offices of Bobbi C. Stemheim
33 West 19th Street - 4th Floor
New York, NY 10011
Phone: 212-243-1100
Attorneys for Ghislaine Maxwell
EFTA00015977

TABLE OF CONTENTS
Page
PRELIMINARY STATEMENT
1
ARGUMENT
2
I.
The Government Concedes that Its Case Relies Almost Exclusively on the
Testimony of Three Witnesses
2
II.
The Government Has Not Carried Its Burden
4
A.
The Government Asks the Court to Ignore Ms. Maxwell's Substantial
Ties to the United States, Including Her Spouse-4
B.
Ms. Maxwell Has Thoroughly Disclosed Her Finances and Pledged All
of Her and Her Spouse's Assets in Support of Her Bond
5
C.
The Government's Assertion that Ms. Maxwell Is "Adept" at Hiding and
Therefore a Flight Risk Is Specious
7
D.
Refusal of Extradition from France or the United Kingdom Is Highly
Unlikely
8
E.
The Recent COVID Surge at MDC Further Justifies Bail
10
CONCLUSION
10
i
EFTA00015978

TABLE OF AUTHORITIES
Pagets)
Cases
United States v. Chen,
820 F. Supp. 1205 (N.D. Cal. 1992)
10
United States v. Orta,
760 F.2d 887 (8th Cir. 1985)
1
EFTA00015979

TABLE OF EXHIBITS
Exhibit A.
Julie Addendum Opinion (France)
Exhibit B.
Perry Addendum Opinion (U.K.)
EFTA00015980

PRELIMINARY STATEMENT
The only issue before the Court is whether conditions exist that can reasonably assure
Ms. Maxwell's appearance during this case. On this renewed application, Ms. Maxwell has put
before the Court a significant bail package, supported by detailed submissio…

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