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efta-efta00065588DOJ Data Set 9Other

Exhibit E

Date
Unknown
Source
DOJ Data Set 9
Reference
EFTA 00065588
Pages
3
Persons
4
Integrity
No Hash Available

Summary

Exhibit E EFTA00065588 Kevin Maxwell The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, NY 10007 Your Honor November 23rd 2020 This statement is in support of Ghislaine Maxwell's request for bail and her character. My name is Kevin Maxwell. I am an entrepreneur working in the real estate development sector specialising in Purpose Built Student Accommodation and social impact residential and infrastructure development. I write this letter in support of my younger sister Ghislaine Maxwell. We are the nearest in age in our surviving family of 7 siblings (I was born in February 1959 and Ghislaine in December 1961) and have always been close since childhood. We remain close and have been in communication by phone and videolink most weeks up until her arrest on July 2nd 2020; I have historically regularly visited her in the United States at least a couple of times a year and she has

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EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
Exhibit E EFTA00065588 Kevin Maxwell The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, NY 10007 Your Honor November 23rd 2020 This statement is in support of Ghislaine Maxwell's request for bail and her character. My name is Kevin Maxwell. I am an entrepreneur working in the real estate development sector specialising in Purpose Built Student Accommodation and social impact residential and infrastructure development. I write this letter in support of my younger sister Ghislaine Maxwell. We are the nearest in age in our surviving family of 7 siblings (I was born in February 1959 and Ghislaine in December 1961) and have always been close since childhood. We remain close and have been in communication by phone and videolink most weeks up until her arrest on July 2nd 2020; I have historically regularly visited her in the United States at least a couple of times a year and she has always caught up with me when she has visited the UK or Europe. I have historically and continue to act as one her closest confidants and advisors, quite apart from our family relationship. Ghislaine has always faced up to every challenge she has met in her life whether it involved confrontations with our father; dealing with the aftermath of his death or decisions involving either her business interests or philanthropic interests. I consider her to be absolutely straight, clear and honest in all her dealings with third parties - this attitude applies to her filing her tax returns as it does to every other aspect of her life: organised, clear and straight. Until these charges, my sister has never been involved in any allegation of breaking the law in any jurisdiction. Speaking for myself, as the father of seven children and grandfather of eight grandchildren, I can confirm that I stand absolutely behind her in her fight to clear her name. In the thirty six years since the birth of my first child, she has been a constant visitor to my family homes, has had my children to stay with her in her homes and has met with all or her great nieces and nephews and I would not hesitate to leave any of my kids or grandkids in her care. I have never witnessed, nor heard from my children or grandchildren any reports of any inappropriate behaviour on my sister's part. Ghislaine has stayed at all times in the jurisdiction of the Unites States since the new charges against the late Jeffrey Epstein and has from the outset confirmed to me personally on EFTA00065589 numerous occasions that she wanted to be available to deal with any civil or criminal allegations, to confront these and to deal with them in situ. She provided evidence under oath in deposition in civil litigation rather than stay silent which is a good illustration of her candour. From my own experience, I can confirm that Ghislaine is kind, thoughtful and generous whether it is helping friends who have fallen on difficult times such as a friend who was recently widowed and to whom Ghislaine provided her own home in London immediately; or inviting my children and their friends when on their gap year to stay with her and to sort out transport, housing and friends to support them on their travels; or whether devoting considerable resources and time to her philanthropic activity primarily in oceans conservation. I have offered to co-sign a bond in the amount of US$3,500,000 where the amount of the bond would be secured by properties owned by my ex-wife Pandora Maxwell as this represents the entirety of realisable family wealth; I do this in support of Pandora's judgement in relation to Ghislaine's integrity and commitment to attend court and to underline that the family would be left without resources in the event that the bond was called. Yours sincerely k • Kevin Maxwell EFTA00065590

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DOJ Data Set 9OtherUnknown

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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

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Exhibit E

Exhibit E EFTA00154352 Kevin Maxwell The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, NY 10007 Your Honor November 23'd 2020 This statement is in support of Ghislaine Maxwell's request for bail and her character. My name is Kevin Maxwell. I am an entrepreneur working in the real estate development sector specialising in Purpose Built Student Accommodation and social impact residential and infrastructure development. I write this letter in support of my younger sister Ghislaine Maxwell. We are the nearest in age in our surviving family of 7 siblings (I was born in February 1959 and Ghislaine in December 1961) and have always been close since childhood. We remain close and have been in communication by phone and videolink most weeks up until her arrest on July 2nd 2020; I have historically regularly visited her in the United States at least a couple of times a year and she has

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