EFTA01977988

UNITED STATES DISTRICT COURT

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

EFTA01594231

FD-302(Itev.5-S-I0)

EFTA00178386

EFTA00178386 United States District Court SOUTHERN DISTRICT OF FLORIDA TO: SUBPOENA TO TESTIFY BEFORE GRAND JURY FGJ 07-103(WPB)-Fti./No. OLY-80/z SUBPOENA FOR: PERSON X DOCUMENTS OR OBJECTISI YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District Court at the place, date and time specified below. PLACE: United States District Courthouse 701 Clematis Street West Palm Beach, Florida 33401 ROOM: Grand Jury Room DATE AND TIME: April 15, 2008 1:00pm YOU ARE ALSO COMMANDED to bring with you the following documents) or object(s): ANY AND ALL NOTES, LETTERS, CARDS, GIFTS, PAYMENTS, AND PHOTOGRAPHS YOU HAVE RECEIVED FROM JEFFREY EPSTEIN, LESLEY GROFF, AND/OR OR ANY EMPLOYEE OF JEFFREY EPST IMI L. ANY AND ALL PHOTOGRAPHS, WHETHER PRINTED OR DIGITAL, OF JEFFREY EPSTEIN, LESLEY GROFF, AND/OR ANY AND ALL E-MAILS, INSTANT MESSAGES, CHATS, TEXT MESSAGES, VOICEMAILS, OR TELEPHONE MESSAGES THAT YOU HAVE SENT TO AND/ORRECEIVED FR

EFTA Document EFTA01481793

SUSPECTED MOTIVE BEHIND GOVERNMENT AND POLICE SOURCES INVOLVED

SUSPECTED MOTIVE BEHIND GOVERNMENT AND POLICE SOURCES INVOLVED IN CONSPIRED COVER UP OF FAMIL L MOLESTATION OF TARGETED VICTIM TH H R BY THE BROTHER FAMILY MEMBER ANTHEThra GATION AND CON- SPIRED ATTACK Or rit /WILY I O DEMORALISE THE DAUGHTER, SISTER AND DISCREDIT HER CREDITABILITY AND TARGETING HER WITH A SEXUAL ABUSE RING CONNECTED TO GOVERNMENT SOURCES AND EPSTEIN AND MAXWELL SUSPECTED MOTIVE OF GOVERNMENT OFFICIALS INVOLVEMENT : COMMENCEMENT - KADINA • JOHN OLSEN - MAYOR OF KADINA - LIBERAL GOVERNMENT MEMBER • ROWAN RAMSAY - FEDERAL GOVERNMENT MEMBER - KADINA AND PORT PIRIE The mother, i= suspected of being sexually active in the community of Kadina as a teenager invo ving sexual interaction with the government officials involved in Kadina John Olsen, Kadina and Rowan Ramsay, Kadina / Port Pine and the overnment officials knowledge of this sexual activity and manipulated by the mother to assist in the family secret cover up under the act of the motive of th