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TABLE OF TENT
Page
PRELIMINARY STATEMENT o.oo. cecceecesecssesneeseesseensecnaesaaesaeesnesseenaecnaesaeesaeesnesaeesaeenaesaaesaeenees
Cased 20-CfQd36O4AuNt Deeuere/ntl 2 0k ed OSPOZQ0P aja DO 2600
(E.D.N.Y. Aug. 4, 2000) (Gleeson, J.) (rejecting defendant’s application for bail in part because
home detention with electronic monitor
Case 21-770, Document 20-2, 04/01/2021, 3068530, Page15 of 200
Exhibit B
Doe. 18
Memorandum of Ghislaine Maxwell In Opposition to the Government’s
Motion for Detention
DOJ-OGR-00000956
Casee1240/CCOOSBOHAGN 2DdcuUMEnt/20 FilecOGAS202P apage ef 1000
In addition, the defendant appears to have access to significant financial resources that
would enable her flight from prosecution. Bas
Case 21-770, Document 20-2, 04/01/2021, 3068530, Page2 of 200
Appendix
Doce. 4 The Government’s Memorandum in Support of Detention.......... A
Doe. 18 Memorandum of Ghislaine Maxwell In Opposition t
Case 21-770, Document 20-2, 04/01/2021, 3068530, Page3 of 200
Doe. 306 United States v. Dashawn Robertson,
Case Number 17-cr-02949-MV1, District of New Mexico
Memorandum Opinion and Order...........c
Case 21-770, Document 20-2, 04/01/2021, 3068530, Page4 of 200
Exhibit A
Doc. 4
The Government’s Memorandum in Support of Detention
DOJ-OGR-00000945
Case 21-770, Document 20-1, 04/01/2021, 3068530, Page31 of 31
CERTIFICATE OF COMPLIANCE
I CERTIFY that this petition complies with the type-volume
limitation of FED. R. App. P. 27. According to Micro
Case 21-770, Document 20-1, 04/01/2021, 3068530, Page30 of 31
CONCLUSION
Ms. Maxwell faces old, anonymous accusations that have never
been tested. In any other case, she would have been released long
Case 21-770, Document 20-1, 04/01/2021, 3068530, Page29 of 31
The Supreme Court has explained that when “the Government
has admitted that its only interest is in preventing flight, bail must be
set b
Case 21-770, Document 20-1, 04/01/2021, 3068530, Page28 of 31
J.). The Constitution’s “prohibitions on the deprivation of liberty
without due process and of excessive bail require careful review of
p
Case 21-770, Document 20-1, 04/01/2021, 3068530, Page27 of 31
constantly monitored. And of course, she is recognizable around the
globe.
The truth is that wealthy men charged with similar or more
se
Case 21-770, Document 20-1, 04/01/2021, 3068530, Page26 of 31
profile is not flight. Ms. Maxwell could have left the United States had
she wanted to flee. She did not want to do that and she did not
Case 21-770, Document 20-1, 04/01/2021, 3068530, Page25 of 31
The government shotguns manufactured assertions in support of
the supposed flight risk. First, the ridiculous contention that she was
hid
Case 21-770, Document 20-1, 04/01/2021, 3068530, Page23 of 31
Recognizing this weakness, the Government relies on the
statutory maximum penalty to argue that the case is serious and that
Ms. Maxwell
Case 21-770, Document 20-1, 04/01/2021, 3068530, Page22 of 31
in making your decision in this case.”); Fifth Circuit: (‘The indictment
. is only an accusation, nothing more. It is not proof of guilt
Case 21-770, Document 20-1, 04/01/2021, 3068530, Page20 of 31
the files around into a different order. She is stuck looking at one page
at a time over a screen three feet away without a lawyer in the
Case 21-770, Document 20-1, 04/01/2021, 3068530, Page19 of 31
officer who issued an order of detention to, by subsequent order,
“permit the temporary release of the person ... to the extent that
th
Case 21-770, Document 20-1, 04/01/2021, 3068530, Page18 of 31
In United States v. Clark, 448 F. Supp. 3d 1152, 1155 (D. Kan.
2020), the court emphasized that “[m]Jost courts addressing a motion for
t
Case 21-770, Document 20-1, 04/01/2021, 3068530, Page16 of 31
the real ability to meet with your lawyers face-to-face while being kept
up all night and being given inedible food makes it virtually im
Case 21-770, Document 20-1, 04/01/2021, 3068530, Page15 of 31
STANDARD OF REVIEW
The question of whether a bail package will reasonably assure the
defendant’s presence is a mixed question of law and
Case 21-770, Document 20-1, 04/01/2021, 3068530, Page14 of 31
motions are pending and raise significant legal bars to the prosecution
of this matter.
C. The proposed bail package
Ghislaine Maxwell
Case 21-770, Document 20-1, 04/01/2021, 3068530, Page11 of 31
evidentiary hearing to test whether the government’s case even
marginally supports detention.
PROCEDURAL HISTORY
A. The arrest and bail
Case 21-770, Document 20-1, 04/01/2021, 3068530, Page8 of 31
flashlight pointed into her cell every 15 minutes. For months, her food
was microwaved with a plastic covering, which rendered it inedible
Case 21-770, Document 20-1, 04/01/2021, 3068530, Page6 of 31
ISSUES PRESENTED
1. Whether Ms. Maxwell can effectively prepare her defense where she
is being subjected to horrific conditions of detent
Case 21-770, Document 20-1, 04/01/2021, 3068530, Paged of 31
Notwithstanding the cries of the mob, Ms. Maxwell is presumed
innocent and is entitled to defend herself. Accordingly, Ms. Maxwell
moves t
Case 21-770, Document 14, 04/01/2021, 3068185, Page‘ of 1
NOTICE OF APPEARANCE FOR SUBSTITUTE, ADDITIONAL, OR AMICUS COUNSEL
Short Title: United States of America v. Maxwell Docket No.: 21-770/21-58
Case 21-770, Document 13, 04/01/2021, 3068158, Page‘ of 2
United States Court of Appeals for the Second Circuit
Thurgood Marshall U.S. Courthouse
40 Foley Square
New York, NY 10007
DEBRA ANN LIVINGS
Case 21-770, Document 13, 04/01/2021, 3068158, Page2 of 2
___ Oversized filing (FRAP 27 (motion), FRAP 32 (brief))
______ Missing Amicus Curiae filing or motion (Local Rule 29.1)
___ Untimely filing
Case 21-770, Document 11, 04/01/2021, 3068130, Page‘ of 2
United States Court of Appeals for the Second Circuit
Thurgood Marshall U.S. Courthouse
40 Foley Square
New York, NY 10007
DEBRA ANN LIVINGS
Case 21-770, Document 3-2, 03/24/2021, 3065978, Page25 of 25
03/24/2021
03/24/2021
Appeal Record Sent to USCA (Electronic File). Certified Indexed record on Appeal
Electronic Files as to Ghislaine
Case 21-770, Document 3-2, 03/24/2021, 3065978, Page13 of 25
09/08/2020 | 54 | LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan dated 8/24/2020
re: Reply in Support of Request to Modif
Case 21-770, Document 3-2, 03/24/2021, 3065978, Page11 of 25
statement might have occurred decades ago and have no relevance to the charges in
this case. These individuals still maintain a significan
Case 21-770, Document 3-2, 03/24/2021, 3065978, Page/ of 25
capacity of the internet platform system, only one attorney per party may participate
by video. Co—counsel, members of the press, and the p
Case 21-770, Document 3-2, 03/24/2021, 3065978, Page4 of 25
Pending Counts
18:371.F CONSPIRACY TO
ENTICE MINORS TO TRAVEL
TO ENGAGE IN ILLEGAL SEX
ACTS
(1)
18:371.F CONSPIRACY TO
ENTICE MINORS TO
Case 21-770, Document 3-2, 03/24/2021, 3065978, Page2 of 25
Alison Gainfort Moe — [email protected], Case [email protected],
[email protected]
Alex Rossmiller [email protected],
Case 21-770, Document 3-1, 03/24/2021, 3065978, Page’ of 1
United States Court of Appeals for the Second Circuit
Thurgood Marshall U.S. Courthouse
40 Foley Square
New York, NY 10007
DEBRA ANN LIVING
CaseGa26-2-00S8@Adhn dd cuimein4BO2 Fikktb6S/22/Pag PayetiWof 12
parallel those that the Court articulated when the Defendant proposed signing an extradition
waiver. See Dec. Op. at 12-13.
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nationality is assessed at the time the offense was committed, any loss of nationality subsequent
to said offense has no bearing upon
CaseGa26-2-00S8 Adin dd Guimein41 B02 Fikkb63/22/PagPageé Wof 12
person as required and the safety of any other person and the community.” 18 U.S.C. §
3142(c)(1)(B). The Court may order that the defe
Case 21-770, Document 1-2, 03/24/2021, 3065965, Page24 of 24
03/24/2021
03/24/2021
Appeal Record Sent to USCA (Electronic File). Certified Indexed record on Appeal
Electronic Files as to Ghislaine
Case 21-770, Document 1-2, 03/24/2021, 3065965, Page12 of 24
09/08/2020 | 54 | LETTER by Ghislaine Maxwell addressed to Judge Alison J. Nathan dated 8/24/2020
re: Reply in Support of Request to Modif
Case 21-770, Document 1-2, 03/24/2021, 3065965, Page10 of 24
statement might have occurred decades ago and have no relevance to the charges in
this case. These individuals still maintain a significan
Case 21-770, Document 1-2, 03/24/2021, 3065965, Page6 of 24
capacity of the internet platform system, only one attorney per party may participate
by video. Co—counsel, members of the press, and the p
Case 21-770, Document 1-2, 03/24/2021, 3065965, Page3 of 24
Pending Counts
18:371.F CONSPIRACY TO
ENTICE MINORS TO TRAVEL
TO ENGAGE IN ILLEGAL SEX
ACTS
(1)
18:371.F CONSPIRACY TO
ENTICE MINORS TO
Case 21-770, Document 1-1, 03/24/2021, 3065965, Page2 of 2
An attorney and any pro se party who is permitted to file documents electronically in CM/ECF
must notify the Court of a change to the user's
Case 21-770, Document 1-1, 03/24/2021, 3065965, Page’ of 2
United States Court of Appeals for the Second Circuit
Thurgood Marshall U.S. Courthouse
40 Foley Square
New York, NY 10007
DEBRA ANN LIVING
Case 19-2221, Document 24, 08/21/2019, 2637838, Page‘ of 1
MANDATE
UNITED STATES COURT OF APPEALS
FOR THE
SECOND CIRCUIT
At a Stated Term of the United States Court of Appeals for the Second Circui
Case 19-2221, Document 23, 08/21/2019, 2637827, Page‘ of 1
UNITED STATES COURT OF APPEALS
FOR THE
SECOND CIRCUIT
At a Stated Term of the United States Court of Appeals for the Second Circuit, held a