EFTA00093044Set 9
2021-04-01382p106,389w
precise. complete statement of relief sough:
Ghislaine Maxwell requests that this Court set
reasonable bail or in the alternative, remand
for an evidentiary hearing.
United States of America v. Ghislaine ... nothing but extremely old, anonymous,
unconfronted, hearsay accusations — to refuse to set reasonable bail.
4
EFTA00093049
Case 21-770, Document 17-1. 04/01/2021. 3068296. Page7 of 31
FACTS
Ghislaine Maxwell ... anything about them.
This case is anything but strong. Ms. Maxwell should be granted
bail or, at the very least, the case should be remanded for an
8
EFTA00093053
Case
https://www.justice.gov/epstein/files/DataSet%209/EFTA00093044.pdf
EFTA00089154Set 9
2020-12-0834p11,257w
submits this memorandum in opposition to the defendant's
renewed motion for release on bail, dated December 8, 2020 (the "Renewed Bail Motion"). Five
months ago, after thorough briefing ... reverse that finding by
essentially repackaging its prior arguments and presenting a more specific bail package. However,
at the July 14, 2020 bail hearing in this case, this Court rejected ... this defendant's appearance. The Court's conclusion was plainly correct,
and the Renewed Bail Motion does nothing to undermine it. The offense conduct outlined in the
Indictment remains incredibly
https://www.justice.gov/epstein/files/DataSet%209/EFTA00089154.pdf
EFTA00086915Set 9
2020-07-1422p6,908w
charges
of perjury, in violation of 18 U.S.C. § 1623. The Court held a lengthy bail hearing on July 14,
2020. After extensive briefing and argument at the hearing, the Court ... flight and that no conditions or combination of conditions would
ensure her appearance. Bail was therefore denied.
The Defendant has now filed a renewed motion for release on bail pending ... Defendant attempts to respond to the
reasons that the Court provided in denying bail and proposes a substantially larger bail package.
But by and large, the arguments presented either were
https://www.justice.gov/epstein/files/DataSet%209/EFTA00086915.pdf
EFTA00079746Set 9
2019-07-1574p18,227w
proceeding, as I'm sure you're
7 all aware, is to conduct a bail hearing. In this matter, as I
8 think you know, the government is seeking continued ... make a
16 recommendation to the Court as to whether there should be bail
17 or detention.
18 There was an additional report -- I think they've
19 gotten additional ... Court,
20 through counsel and through the government counsel, that they
21 oppose bail for Mr. Epstein. They may also be heard today in
22 court if they wish
https://www.justice.gov/epstein/files/DataSet%209/EFTA00079746.pdf
EFTA01090709Set 9
264p121,227w
indicated by the facts of the case, seek the setting of a reasonable bail, and otherwise represent the
defendant pending a formal judicial determination of indigency.
(B) If the defendant ... liberty on bail or otherwise not in custody, the public defender shall elicit from the
defendant only the information that may be reasonably relevant to the question of indigency ... offenses bailable as of right be endorsed with the amount of bail and the return date.
(b) Amendment. No arrest warrant shall be dismissed nor shall any person in custody
https://www.justice.gov/epstein/files/DataSet%209/EFTA01090709.pdf
EFTA00266717Set 9
5p1,921w
egeti No-r ERnuoocarr Y'
FOFtM 004
Trans No: 000631016
Bail No : 10/Q33059
AP No : 10/Q33048
Fr" „ t.. , AUSTRALIA
POOR? - /1.4 t '"er 1985, Section 6(2)
PAST ... listed •nt.
1UNDERSTA' • ply with a condition of bail -
-I may be LI
— I may have
:11 breach this agreement; AND
- I may be co. • to a maximum penalty ... years impris ••• •
CONDITIONS
1. l agree that 1 o . . :ruler the Bail Act 1985.1
2. I agree that -
(a) I u." •
(b) i y1/4
(c) I , h 4 term
https://www.justice.gov/epstein/files/DataSet%209/EFTA00266717.pdf
EFTA00151417Set 9
2020-07-1026p7,996w
Circumstances of the Charges and the Weight of
the Evidence Militate in Favor of Bail 17
3. The Proposed Bail Package Is More Than Adequate to Secure
Ms. Maxwell ... treated like any other defendant who comes
before this Court, including as to bail. Under the Bail Reform Act, case law in this Circuit and
other circuits, as well ... decisions of this Court, Ms. Maxwell should be released on bail, subject
to the strict conditions proposed below.
EFTA00151421
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page
https://www.justice.gov/epstein/files/DataSet%209/EFTA00151417.pdf
EFTA01653624Set 10
2020-07-1026p7,996w
Circumstances of the Charges and the Weight of
the Evidence Militate in Favor of Bail 17
3. The Proposed Bail Package Is More Than Adequate to Secure
Ms. Maxwell ... treated like any other defendant who comes
before this Court, including as to bail. Under the Bail Reform Act, case law in this Circuit and
other circuits, as well ... decisions of this Court, Ms. Maxwell should be released on bail, subject
to the strict conditions proposed below.
EFTA01653628
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01653624.pdf
EFTA00083324Set 9
2020-07-1026p7,996w
Circumstances of the Charges and the Weight of
the Evidence Militate in Favor of Bail 17
3. The Proposed Bail Package Is More Than Adequate to Secure
Ms. Maxwell ... treated like any other defendant who comes
before this Court, including as to bail. Under the Bail Reform Act, case law in this Circuit and
other circuits, as well ... decisions of this Court, Ms. Maxwell should be released on bail, subject
to the strict conditions proposed below.
EFTA00083328
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page
https://www.justice.gov/epstein/files/DataSet%209/EFTA00083324.pdf
EFTA00104625Set 9
2020-07-1026p7,996w
Circumstances of the Charges and the Weight of
the Evidence Militate in Favor of Bail 17
3. The Proposed Bail Package Is More Than Adequate to Secure
Ms. Maxwell ... treated like any other defendant who comes
before this Court, including as to bail. Under the Bail Reform Act, case law in this Circuit and
other circuits, as well ... decisions of this Court, Ms. Maxwell should be released on bail, subject
to the strict conditions proposed below.
EFTA00104629
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page
https://www.justice.gov/epstein/files/DataSet%209/EFTA00104625.pdf
EFTA00104533Set 9
18p5,128w
issue before the Court, as it has been since Ms. Maxwell's first bail application,
is whether conditions exist that can reasonably assure Ms. Maxwell's appearance at trial ... third application (the "Third Bail Motion") (Dkt.160), Ms. Maxwell has put before
the Court significant enhancements to the already extraordinary bail package previously
presented to the Court in her renewed ... application for bail (the "Second Bail Motion")
(Dkt. 97).' Together, these two motions present a unique and comprehensive bail package
with the strictest of conditions known in any bail application
https://www.justice.gov/epstein/files/DataSet%209/EFTA00104533.pdf
EFTA00081947Set 9
2019-07-0833p10,720w
REMANDING DEFENDANT
JEFFREY EPSTEIN,
Defendant.
x
A. Background
This ruling follows the Court's bail hearing held on July IS, 2019. The issue before the
Court is whether the Defendant ... remanded. Victims have, among other things, been given the opportunity to testify at the bail
hearing.
B. Counsels' Submissions
The Government's letter application, dated July 8, 2019, requests that ... experience with this Defendant, that "if [Mr. Epstein is] allowed to remain out
on bail, the defendant could attempt to pressure and intimidate witnesses and potential witnesses
in this case
https://www.justice.gov/epstein/files/DataSet%209/EFTA00081947.pdf
EFTA00039383Set 9
2019-07-0833p10,702w
REMANDING DEFENDANT
JEFFREY EPSTEIN,
Defendant.
x
A. Background
This ruling follows the Court's bail hearing held on July IS, 2019. The issue before the
Court is whether the Defendant ... remanded. Victims have, among other things, been given the opportunity to testify at the bail
hearing.
B. Counsels' Submissions
The Government's letter application, dated July 8, 2019, requests that ... experience with this Defendant, that "if [Mr. Epstein is] allowed to remain out
on bail, the defendant could attempt to pressure and intimidate witnesses and potential witnesses
in this case
https://www.justice.gov/epstein/files/DataSet%209/EFTA00039383.pdf
EFTA00266722Set 9
2009-10-266p1,548w
FORM 7 - BAIL ACT 1985 (Section 6(4))
APPLICATION TO VARY THE CONDITIONS OF A BAIL AGREEMENT
APPLICATION TO REVOKE BAIL AGREEMENT
PART A: APPLICATION
__(Insertfull name _o_fperson released ... bail) .....
of (insert address)
is charged with / has-bean-aeftvieted-ef-* ersic, er-asourr
and was granted bail on
I, (insert name ofapplicant) "ittCS.V.eivitic- Crier:iv-Mc 174ittrarnif>
of (insert ... address)
apply to (insert name of bail authority) .
at Port Pine 010\915.tratees Court.
to - * vary the conditions of the bail agreement
2.4,0w3k.414.4 64.egreement__
I make this application
https://www.justice.gov/epstein/files/DataSet%209/EFTA00266722.pdf
EFTA00027360Set 8
2020-07-1412p3,752w
violation of 18 U.S.C. § 1623.
On July 14, 2020, the Court held a lengthy bail hearing and concluded that the Defendant
was a clear risk of flight and that ... conditions or combination of conditions would ensure her
appearance. It therefore denied bail. On December 8, 2020, the Defendant filed a renewed
motion for release on bail pending trial, which ... Defendant then filed a third motion for release on bail on February 23, 2021. Dkt.
No. 160. In this motion, the Defendant attempts to respond to the reasons that
https://www.justice.gov/epstein/files/DataSet%208/EFTA00027360.pdf
EFTA00104521Set 9
2020-07-1412p3,749w
violation of 18 U.S.C. § 1623.
On July 14, 2020, the Court held a lengthy bail hearing and concluded that the Defendant
was a clear risk of flight and that ... conditions or combination of conditions would ensure her
appearance. It therefore denied bail. On December 8, 2020, the Defendant filed a renewed
motion for release on bail pending trial, which ... Defendant then filed a third motion for release on bail on February 23, 2021. Dkt.
No. 160. In this motion, the Defendant attempts to respond to the reasons that
https://www.justice.gov/epstein/files/DataSet%209/EFTA00104521.pdf