EFTA02142862

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DOJ Data Set 10

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efta-02142862

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EFTA Disclosure

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To: undisclosed-reci ients: lice: From: Will Ford Sent: Mon 4/8/2013 10:42:22 AM Subject: Apr 8th tidbits & quotes "What you can't do in one day you must do in two." - East Anglian proverb "Sign your own checks." - Bill Cosby, advice to Oprah Winfrey "The rifle is the first weapon you learn how to use, because it lets you keep your distance from the client. The closer you get to being a pro, the closer you can get to the client. The knife, for example, is the last thing you learn." - Loon, the Professional "As I grow older, I pay less attention to what men say. I just watch what they do." - Andrew Carnegie Jed Clampett: What do you think Pearl? You think I oughta move? Cousin Pearl Bodine: Jed, how can you even ask? Look around you. You live eight miles from your nearest neighbor. You're overrun with skunks, possums, coyotes, and bobcats. You use kerosene lamps for fight. You cook on a wood stove, summer and winter. You're drinkin' homemade moonshine, and washin' with homemade lye soap. And your bathroom is fifty feet from the house. And you ask should you move!? Jed Clampett: [ponders] Yeah, I reckon you're right. Man'd be a dang fool to leave all this. EFTA_R1_00798890 EFTA02142862

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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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Filing # 33747975 E-Filed 10/27/2015 04:45:57 PM

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