EFTA02333447

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

EFTA00016262

EFTA01576125

Alfredo Rodriguez’s stolen “golden nugget” – a bound book linking Jeffrey Epstein to dozens of world leaders and billionaires

The passage describes a former Epstein employee, Alfredo Rodriguez, who allegedly stole a bound book containing the names, addresses and phone numbers of high‑profile individuals (e.g., Henry Kissinge Rodriguez claims the book lists names, addresses and phone numbers of dozens of influential individu He tried to sell the book to an undercover FBI agent for $50,000, indicating awareness of its valu

EFTA00014393

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK In re: Second Warrant and Order For Prospective and Historical Location Information and Pen Register Information for the Cell hone Assigned Call Number , USAO Reference No. 2018R01618 AMENDED APPLICATION Amended Application for Second Warrant and Order for Cellphone Location and Pen Register Information Mag. The United States of America, by its attorney, Audrey Strauss, Acting United States Attorney for the Southern District of New York, Assistant United States Attorney, of counsel, respectfully requests that the Court issue the accompanying proposed Second Warrant and Order for prospective and historical location information and pen register information for a cellphone. As grounds for this Amended Application the Government relies on the following facts and authorities. I. Introduction I. lam an Assistant United States Attorney in the U.S. Attorney's Office for the Southern District of New York. This