COHEN & GRESSER LLP
Summary
COHEN & GRESSER LLP Christian R. May 28, 2021 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Dear Judge Nathan: 800 Third Avenue New Yak NY 10022 swess r .c resiterom On behalf of our client, Ghislaine Maxwell, we will be filing our Omnibus Reply Memorandum in Support of Ms. Maxwell's Supplemental Pretrial Motions Relating to the S2 Superseding Indictment. The reply memorandum contains Confidential Information produced in discovery that is governed by paragraph 15 of the Protective Order (Dkt. 36). Accordingly, pursuant to our prior practice, we will not file the reply memorandum on the public docket until we are instructed to do so by the Court. Instead, we will submit the reply memorandum by email to the Court and the government under seal—pursuant to Rule 2(B) of the Court's individual rules of criminal practice—to
Persons Referenced (3)
Tags
Search 264K+ documents with AI-powered analysis
Extracted Text (OCR)
EFTA DisclosureRelated Documents (6)
Court Transcript: 773
The transcript details a segment of Ghislaine Maxwell's jury trial where the jury requests supplies and a definition for 'enticement'. The prosecution and defense discuss how to respond, with the judge referencing previous cases (United States v. Almonte and United States v. Dupigny) to define 'entice' as 'to attract, induce, or lure using hope or desire'.
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
LBUCmaxl
120 LBUCmaxl UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. Before: 20 CR 330 (AJN) Jury Trial New York, N.Y. November 30, 2021 8:50 a.m. HON. ALISON J. NATHAN, APPEARANCES DAMIAN United States Attorney for the Southern District of New York BY: Assistant United States Attorneys HADDON MORGAN AND FOREMAN Attorneys for Defendant BY: JEFFREY S. PAGLIUCA CHRISTIAN R. EVERDELL LAURA A. MENNINGER -and- BOBBI C. STERNHEIM -and- RENATO STABILE Also Present: District Judge , FBI NYPD Sunny Drescher, Paralegal, U.S. Attorney's Office Ann Lundberg, Paralegal, Haddon Morgan and Foreman SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068582 121 LBUCmaxl 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (Jury not present) THE COURT: Looks like we have everybody. Matt
Court Filing: 123
Ghislaine Maxwell's defense team filed a motion to dismiss Counts One through Four of the superseding indictment for lack of specificity. The motion was filed on January 25, 2021, in the United States District Court for the Southern District of New York. The defense team is represented by multiple attorneys from different law firms.
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 IN SUPPORT OF GHISLAINE MAXWELL'S THIRD MOTION FOR RELEASE ON BAIL Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Attorneys for Ghislaine Maxwell EFTA00090990 INTRODUCTION Ghislaine Maxwell respectfully submits this Memorandum in Support of her Third Motion for Release on Bail. As Ms. Maxwell has stated on numerous occasions and reaffirms here: she has no intention or desire to leave this country. She is an American citizen, has lived in United States for 30 years, has strong family ties and the support of friends and family residing in this country. She wants nothing more than to remain in the United States under whatever conditions the Court deems necessary so that she can effectively prepare fo
Court Filing: 121
Ghislaine Maxwell's defense team filed a motion to dismiss either Count One or Count Three of the superseding indictment, arguing that they are multiplicitous. The motion was filed on January 25, 2021, in the United States District Court for the Southern District of New York. The defense team is represented by multiple attorneys from different law firms.
Forum Discussions
This document was digitized, indexed, and cross-referenced with 1,400+ persons in the Epstein files. 100% free, ad-free, and independent.