Exhibit G
Summary
Exhibit G EFTA00154365 151 December 2020 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, This letter is provided by way of support for the release on bail of my sister. Ghislaine Maxwell, the youngest of my six siblings to whom I have long been close as she and our brother Kevin — respectively five and three years younger than me - were the youngest in our family and were effectively brought up together. Ghislaine and I have always remained in close touch. During the last 30 years or so this has been primarily by phone and email as Ghislaine has lived for the greater part of that time in the US whilst I live in London. On my last two trips to the US in February 2013 and in December 2018 I stayed with her for about a week on both occasions and she always made a point of seeing me whenever she came through London. In addition to our family relationship, in a
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Exhibit G
Exhibit G EFTA00065666 15' December 2020 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, This letter is provided by way of support for the release on bail of my sister. Ghislaine Maxwell, the youngest of my six siblings to whom I have long been close as she and our brother Kevin — respectively five and three years younger than me - were the youngest in our family and were effectively brought up together. Ghislaine and I have always remained in close touch. During the last 30 years or so this has been primarily by phone and email as Ghislaine has lived for the greater part of that time in the US whilst I live in London. On my last two trips to the US in February 2013 and in December 2018 I stayed with her for about a week on both occasions and she always made a point of seeing me whenever she came through London. In addition to our family relationship, in a
UNCLASSIFIED//LAW ENFORCEMENT SENSITIVE
UNCLASSIFIED//LAW ENFORCEMENT SENSITIVE FBI INTERNAL USE ONLY - DO NOT DISSEMINATE EXTERNALLY Template Met-tire 10-1-2021 Tactical Intelli. FBI New York, ID-13 22 March 2022 50D-NY-3027571-INTELPRODS (U) LAW ENFORCEMENT SENSITIVE: The information marked (U//LES) in this document is the property of the Federal Bureau of Investigation (FBI) and is for internal use within the FBI only. Distribution outside the FBI without FBI New York's authorization is prohibited. Precautions should be taken to ensure this information is stored and/or destroyed in a manner that precludes unauthorized access. Information bearing the LES caveat may not be used in legal proceedings without first receiving authorization from the originating office. Recipients are prohibited from subsequently posting the information marked LES on a website on an unclassified network. (U) This document is classified Unclassified//Law Enforcement Sensitive. (U) This document is only for FBI internal use. Do not ext
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
UNCLASSIFIED//LAW ENFORCEMENT SENSITIVE
UNCLASSIFIED//LAW ENFORCEMENT SENSITIVE FBI INTERNAL USE ONLY - DO NOT DISSEMINATE EXTERNALLY Template IWectire 10-1-2021 Tactical Intelli. ence Report FBI New York, ID-13 14 February 2022 50D-NY-3027571-INTELPRODS (U) LAW ENFORCEMENT SENSITIVE: The information marked (U//LES) in this document is the property of the Federal Bureau of Investigation (FBI) and is for internal use within the FBI only. Distribution outside the FBI without FBI New York's authorization is prohibited. Precautions should be taken to ensure this information is stored and/or destroyed in a manner that precludes unauthorized access. Information bearing the LES caveat may not be used in legal proceedings without first receiving authorization from the originating office. Recipients are prohibited from subsequently posting the information marked LES on a website on an unclassified network. (U) This document is classified Unclassified//Law Enforcement Sensitive. (U) This document is only for FBI internal
UNCLASSIFIED//LAW ENFORCEMENT SENSITIVE
UNCLASSIFIED//LAW ENFORCEMENT SENSITIVE FBI INTERNAL USE ONLY - DO NOT DISSEMINATE EXTERNALLY Template Effective 10-1-2021 Tactical ntelligence Re FBI New York, ID-13 23 February 2022 50D-NY-3027571-INTELPRODS (U) LAW ENFORCEMENT SENSITIVE: The information marked (U//LES) in this document is the property of the Federal Bureau of Investigation (FBI) and is for internal use within the FBI only. Distribution outside the FBI without FBI New York's authorization is prohibited. Precautions should be taken to ensure this information is stored and/or destroyed in a manner that precludes unauthorized access. Information bearing the LES caveat may not be used in legal proceedings without first receiving authorization from the originating office. Recipients are prohibited from subsequently posting the information marked LES on a website on an unclassified network. (U) This document is classified Unclassified//Law Enforcement Sensitive. (U) This document is only for FBI internal use.
UNCLASSIFIED//LAW ENFORCEMENT SENSITIVE
UNCLASSIFIED//LAW ENFORCEMENT SENSITIVE FBI INTERNAL USE ONLY - DO NOT DISSEMINATE EXTERNALLY Template Effective 10-1-2021 'ence Report FBI New York, ID-13 8 February 2022 50D-NY-3027571-INTELPRODS (U) LAW ENFORCEMENT SENSITIVE: The information marked (U//LES) in this document is the property of the Federal Bureau of Investigation (FBI) and is for internal use within the FBI only. Distribution outside the FBI without FBI New York's authorization is prohibited. Precautions should be taken to ensure this information is stored and/or destroyed in a manner that precludes unauthorized access. Information bearing the LES caveat may not be used in legal proceedings without first receiving authorization from the originating office. Recipients are prohibited from subsequently posting the information marked LES on a website on an unclassified network. (U) This document is classified Unclassified//Law Enforcement Sensitive. (U) This document is only for FBI internal use. Do not ext
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