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For the rest of the decision, Maxwell rested her head in her hands as she had done at the 
start of the hearing. 
Maxwell sat though prosecutors detailing how she was 'skilled at living in hiding' and as 
two victims argued she was a flight risk, with one writing: 'Without Ghislaine, Jeffrey 
couldn't have done what he did. She is a predator and a monster.' 
Prosecutors argued against Maxwell being granted bail, citing that due to holding both 
French and British passports, she has the ability to 'live beyond the reach of extradition 
indefinitely'. 
Prosecutor 
argued: 'She is good at living under an assumed identity. There really 
can be no question that she can live in hiding.' 
She revealed when Maxwell bought her $1 million home in Bradford, New Hampshire last 
December, she toured the property with a real estate agent using an alias. 
said: 'The real estate agent told the FBI agent the buyers for the house introduced 
themselves as Scott and Janet Marshall. Both had British accents. 
'Scott Marshall told her he was retired from the British military and was currently working 
on a book. Janet Marshall described herself as a journalist.' 
Last summer, DailyMail.com previously tracked down Maxwell in Manchester-by-the-Sea, 
living at a home owned by her tech CEO lover Scott Borgerson. It is unclear if the man 
who toured the New Hampshire home with Maxwell was Borgerson. 
also read out a victim impact statement from a woman identified as Jane Doe, who 
also made the case that Maxwell was a flight risk. 
The victim said she knew Maxwell for 10 years and the socialite intended to 'deliver' her 
to Epstein, all the while knowing the 'heinous dehumanization that awaited me'. 
The woman claimed Maxwell 'was in charge' and 'egged' Epstein on. 
She described Maxwell as 'sociopathic' and said she would 'have done anything to get 
what she wanted - to satisfy Jeffrey Epstein'. 
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Victim 
ictured) also spoke at the hearing, detailing how she met Maxwell when 
she was 
years o . 
has previously gone on record with her claims against Maxwell 
Prosecutor 
said when Maxwell bought her S1 million Bradford, New Hampshire 
home (pictured), she toured the home back in November of 2019 using the alias of Janet 
Marshall and claimed to the real estate agent that she worked as a journalist 
The victim added that 'if [Maxwell] is out, I need to be protected', citing a phone call she 
received in the middle of the night threatening her two-year-old child. 
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Iso spoke at the hearing, detailing how she met Maxwell when she was 16 
has previously gone on record with her claims against Maxwell. 
She said Maxwell 'has never shown any remorse [andj tormented her survivors... She has 
associates across the globe, some of great means.' 
Maxwell's attorney Mark Cohen tried to argue his client was not a flight risk, claiming she 
has community ties and is 'part of a very large and close family'. 
He said: 'Our client is not Jeffrey Epstein, and she has been the target of endless media 
spin', leading prosecutor. to later shoot back: 'These are the facts. It is not dirt, it is 
not spin, it is evidence to the court.' 
Cohen claimed Maxwell had received numerous threats and denied she had refused to 
open her front door to the FBI when they raided her home on July 2. 
He claimed her front door was unlocked, the windows were open and she had 
'surrendered' to the agents. 
Addressing reports that Maxwell had wrapped her mobile phone in tin foil, which 
prosecutors called a 'seemingly misguided effort to evade detection' by law enforcement, 
Cohen claimed her phone had been hacked and she had to preserve the phone as 
evidence. 
MAXWELL'S LEGAL TEAM: Pictured l-r: Jeffrey S. Pagliuca,Christian R Everdell, Laura A. 
Menninger and Mark Cohen. In their filings to the court Maxwell's lawyers had argued that she 
is at increased risk of catching the coronavirus whilst in prison. They claim that the restrictions 
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Pictured: Acting United States Attorney for the Southern District of New York Audrey Strauss 
speaks during a news conference to announce charges against Ghislaine Maxwell 
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Cohen went above the issue of Maxwell being a flight risk to complain that the charges 
against her are from 25 years ago, calling the indictment 'an effort to dance around' the 
controversial non-prosecution sweetheart deal Epstein and his associates received in 
Florida in 2007. 
With her bail now denied, Maxwell will return to the Metropolitan Detention Center in 
Brooklyn. 
Journalists had started lining up outside the federal court in downtown Manhattan at 6am 
to get a seat inside the courtroom. 
They were allowed in at 11.45am and had to stand 6ft apart while they waited to ensure 
social distancing. 
The hearing took place in the jury assembly room which normally has space for hundreds 
of people but had a dramatically reduced capacity of just 60 due to the coronavirus. 
A dial-in phone line allowed 1,000 more people to listen in - the capacity was increased 
from 500 due to world-wide interest. 
Inside the room there were two projector screens, which showed the proceedings live. 
All parties, including the judge, appeared remotely and no one was physically in court. 
Maxwell's lawyer was visible at all times in a box on the screen. Maxwell had her own 
box, the judge had one and the prosecutors had another. 
Maxwell's mugshot has not been released by the federal authorities and the hearing 
offered the first chance to see her in at least a year. 
Maxwell's whereabouts had largely been unknown since Epstein's arrest last July. 
Although DailyMail.com tracked her down to the New England coast last summer, she 
vanished again, later popping up in a photo at an In-N-Out in Los Angeles. 
The FBI managed to finally trace her down in the quiet and rural town of Bradford, New 
Hampshire earlier this month, where she had been living since December. 
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Maxwell's mugshot has not been released by the federal authorities and the hearing offered the 
first chance to see her in at least a year. Maxwell's whereabouts had largely been unknown 
since Epstein's arrest last July. Although DailyMail.com tracked her down to the New England 
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coast last summer, she vanished again, later popping up in a photo at an In-N-Out in Los 
Angeles 
M Patric k Me Marten en Cm ay Images 
Maxwell was romantically involved with Jeffrey Epstein from around 1992, but then became his 
'right-hand woman', managing his property empire and, it is alleged, his trafficking of minors 
Officials said her conduct during the 8.30am raid at the property called 'Tuckedaway' was 
'troubling'. 
They wrote that when the FBI arrived they were confronted by a locked gate which they 
forced their way through. 
The filing said: 'As the agents approached the front door to the main house, they 
announced themselves as FBI agents and directed the defendant to open the door. 
'Through a window, the agents saw the defendant ignore the direction to open the door 
and, instead, try to flee to another room in the house, quickly shutting a door behind her. 
Agents were ultimately forced to breach the door in order to enter the house to arrest the 
defendant, who was found in an interior room in the house. 
'Moreover, as the agents conducted a security sweep of the house, they also noticed a 
cell phone wrapped in tin foil on top of a desk, a seemingly misguided effort to evade 
detection, not by the press or public, which of course would have no ability to trace her 
phone or intercept her communications, but by law enforcement'. 
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After Maxwell, the daughter of late newspaper tycoon Robert Maxwell, was arrested the 
FBI spoke to a security guard who worked on the property who said that her brother had 
hired him from a company staffed with former British military soldiers. 
The filing states: 'The guard informed the FBI that the defendant had not left the property 
during his time working there, and that instead, the guard was sent to make purchases for 
the property using the credit card. As these facts make plain, there should be no question 
that the defendant is skilled at living in hiding'. 
In their filings to the court Maxwell's lawyers had argued that she is at increased risk of 
catching the coronavirus whilst in prison. So far there have only been five cases and no 
deaths at the prison. 
They claim that the restrictions on access to her lawyers caused by the pandemic would 
mean it was impossible for her to get a fair trial. 
The prosecutors said that in fact the prison had made substantial efforts to accommodate 
her and keep her safe. 
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Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 2 of 19 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
x 
UNITED STATES OF AMERICA 
20 Cr. 330 (AJN) 
GHISLA1NE MAXWELL, 
Defendant. 
x 
THE GOVERNMENT'S REPLY MEMORANDUM 
IN FURTHER SUPPORT OF DETENTION 
The Government respectfully submits this reply memorandum in further support of its 
motion for detention, dated July 2, 2020 (the "Detention Memorandum") (Dkt. 4), and in response 
to the defendant's memorandum in opposition (the "Opposition Memorandum") (Dkt. 18). 
The charges against Ghislaine Maxwell arise from her essential role in sexual exploitation 
that caused deep and lasting harm to vulnerable victims. At the heart of this case are brave women 
who are victims of serious crimes that demand justice. The defendant's motion wholly fails to 
appreciate the driving force behind this case: the defendant's victims were sexually abused as 
minors as a direct result of Ghislaine Maxwell's actions, and they have carried the trauma from 
these events for their entire adult lives. They deserve to see her brought to justice at a trial. 
There will be no trial for the victims if the defendant is afforded the opportunity to flee the 
jurisdiction, and there is every reason to think that is exactly what she will do if she is released. 
For the reasons detailed in the Detention Memorandum, and as further discussed below, the 
defendant poses a clear risk of flight, and no conditions of bail could reasonably assure her 
continued appearance in this case. Among other concerns: (1) she is a citizen of a country that 
does not extradite its own citizens; (2) she appears to have access to considerable wealth 
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Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 3 of 19 
domestically and abroad; (3) her finances are completely opaque, as her memorandum pointedly 
declines to provide the Court with information about her financial resources; and (4) she appears 
to be skilled at living in hiding. These are glaring red flags, even before the Court considers the 
gravity of the charges in this case and the serious penalties the defendant faces if convicted at trial. 
Instead of attempting to address the risks of releasing a defendant with apparent access to 
extraordinary financial resources, who has the ability to live beyond the reach of extradition in 
France, and who has already demonstrated a willingness and ability to live in hiding, the defendant 
instead proposes a bail package that amounts to little more than an unsecured bond. Among other 
things, the proposed bail package contemplates the defendant pledging as the sole security a 
property that is beyond the territory and judicial reach of the United States, and which therefore is 
of no value as collateral. She proposes six unidentified co-signers, an unknown number of whom 
even reside in the United States, and stone of whose assets are identified. The Court and the 
Government have no information whatsoever regarding whether these co-signers would be able to 
able to pay the proposed $5 million bond should the defendant flee — or if, of equal concern, the 
co-signers are themselves so wealthy that it would be no financial burden whatsoever to do so. 
The defendant does not identify what residence she proposes to live at in the Southern District of 
New York, nor does she identify any meaningful ties to the area. And most importantly, the 
defendant's memorandum provides the Court with no information whatsoever about her own 
finances or her access to the wealth of others, declining to provide the Court the very information 
that would inform any decision about whether a bond is even meaningful to the defendant — and 
which the Government submits would reveal the defendant's financial means to flee and live 
comfortably abroad for the rest of her life. 
2 
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Finally, the Government recognizes that the COVID-19 pandemic is — and should be — a 
relevant factor for the Court and the parties in this case. However, the Bureau of Prisons ("BOP") 
is taking very significant steps to address that concern, and the defendant has offered no reason 
why she should be treated any differently from the many defendants who are currently detained at 
the Metropolitan Detention Center ("MDC") pending trial, including defendants who have medical 
conditions that place them at heightened risk. Inmates at the MDC are able to assist in their own 
defense, especially long before trial, through established policies and procedures applicable to 
every pretrial detainee. This defendant should not be granted the special treatment she requests. 
The defendant faces a presumption of detention, she has significant assets and foreign ties, 
she has demonstrated her ability to evade detection, and the victims of the defendant's crimes seek 
her detention. Because there is no set of conditions short of incarceration that can reasonably 
assure the defendant's appearance, the Government urges the Court to detain her. 
ARGUMENT 
Each of the relevant factors to be considered as to flight risk — the nature and circumstances 
of the offense, the strength of the evidence, and the history and characteristics of the defendant — 
weigh strongly in favor of detention, and the defendant's proposed package would do absolutely 
nothing to mitigate those risks. 
I. 
The Defendant's Victims Seek Detention 
As the Court is aware, pursuant to the Crime Victims' Rights Act ("CVRA"), a crime 
victim has the right to be reasonably heard at certain public proceedings in the district court, 
including proceedings involving release. 18 U.S.C. § 377 l(a)(4). 
Consistent with that 
requirement, the Government has been in contact with victims and their counsel in connection with 
its application for detention. Counsel for one victim has already conveyed to the Government that 
3 
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Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 5 of 19 
their client opposes bail for the defendant, and has asked the Government to convey that view to 
the Court. The Government also expects that one or more victims will exercise their right to be 
heard at the July 14, 2020 hearing in this matter, and will urge the Court not to grant bail. More 
generally, as noted above, the Government is deeply concerned that if the defendant is bailed, the 
victims will be denied justice in this case. That outcome is unacceptable to both the victims and 
the Government. 
II. 
The Government's Case Is Strong 
The defendant's motion argues, in a conclusory fashion, that the Government's case must 
be weak because the conduct charged occurred in the 1990s. That argument, which ignores the 
many specific allegations in the Indictment, could not be more wrong. As the superseding 
indictment (the "Indictment") makes plain, multiple victims have provided detailed, credible 
evidence of the defendant's criminal conduct. And while that conduct did take place a number of 
years ago, it is unsurprising that the victims have been unable to forget the defendant's predatory 
conduct after all this time, as traumatic childhood experiences often leave indelible marks. The 
recollections of the victims bear striking resemblances that corroborate each other and provide 
compelling proof of the defendant's active participation in a disturbing scheme to groom and 
sexually abuse minor girls. In addition to compelling victim accounts, as the Government has 
explained, the victims' accounts are corroborated by documentary evidence and other witnesses. 
In particular, the victims' accounts are supported by contemporaneous documents and 
records, such as flight records, diary entries, and business records. The powerful testimony of 
these victims, who had strikingly similar experiences with Maxwell, together with documentary 
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evidence and witness testimony, will conclusively establish that the defendant groomed the victims 
for sexual abuse by Jeffrey Epstein.' 
The defendant's motion alludes to defenses in this case, all of which are legal or procedural 
in nature, and none of which pass muster, let alone counsel in favor of bail. To begin with, the 
notion that the defendant is protected from prosecution by the Non-Prosecution Agreement 
("NPA") between Jeffrey Epstein and the U.S. Attorney's Office in the Southern District of Florida 
("SDFL") is absurd. That agreement affords her no protection in this District, for at least three 
reasons. First, the defendant was not a party to that agreement nor named in it as a third-party 
beneficiary, and the defendant offers no basis to think she would have standing to claim any rights 
under the NPA. Tellingly, the defendant cites no authority for the proposition that an agreement 
she was not a party to and that does not even identify her by name could possibly be invoked to 
bar her prosecution. Second, and equally important, the NPA does not bind the Southern District 
of New York, which was not a party to the agreement. See (lulled States v. Annabl, 771 F.2d 670, 
672 (2d Cir. 1985) (per curiam) ("A plea agreement binds only the office of the United States 
Attorney for the district in which the plea is entered unless it affirmatively appears that the 
agreement contemplates a broader restriction.")); (lulled States v. Prim), 391 F. App'x 920, 921 
(2d Cir. 2010). This rule applies even when the text of the agreement refers to the signing party 
as the "Government." Annab1, 771 F.2d at 672. 
Third, and perhaps most important, even assuming the NPA could be read to protect this 
defendant and bind this Office, which are both legally unsound propositions, the Indictment 
Additionally, and beyond the strong evidence set forth in the Indictment, in just the past week, 
and in response to the charges against the defendant being made public, the Federal Bureau of 
Investigation ("FBI") and the U.S. Attorney's Office have been in touch with additional 
individuals who have expressed a willingness to provide information regarding the defendant. The 
Government is in the process of receiving and reviewing this additional evidence, which has the 
potential to make the Government's case even stronger. 
5 
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New York prosecutors said in a filing Monday this was evidence that Maxwell was 'skilled at 
living in hiding' and should be denied bail 
Proposed Boil Conditions. In light of the above, we propose the following bail 
conditions, which are consistent with those that courts in this Circuit have imposed in analogous 
situations: 01 a S5 million personal recognizance bond, co-signed by six financially responsible 
i eople, all of whom have strong ties to Ms. Maxwell, and secured by real property in the United 
kingdom worth over 53.75 million; (ii) travel restricted to the Southern and Eastern Districts of 
New York; (iii) surrender of all travel documents with no new applications; (iv) strict 
supervision by Pretrial Services: ( v ) home confinement at a residence in the Southern District of 
New York with electronic GPS monitoring; (vi) visitors limited to Ms. Maxwell's immediate 
family, close friends and counsel; (vii) travel limited to Court appearances and to counsel's 
office, except upon application to Pretrial Services and the government; and (viii) such other 
terms as the Court may deem appropriate under Section 3142.
Her bail request (pictured) was filed in the US District Court in Manhattan and claims she was 
not 'hiding' from authorities, is not a flight risk and is at risk of contracting COVID-19 if she 
continues to be held in the Brooklyn jail 
The case against her is 'strong' and multiple victims have provided 'detailed, credible 
evidence of the defendant's criminal conduct' - with more women coming forward in the 
past week. 
The victims have made clear they want Maxwell remanded in custody and say they were 
'directly abused as a result of Ghislaine Maxwell's actions'. 
The document states: 'While that conduct did take place a number of years ago, it is 
unsurprising that the victims have been unable to forget the defendant's predatory 
conduct after all this time, as traumatic childhood experiences often leave indelible marks. 
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'The recollections of the victims bear striking resemblances that corroborate each other 
and provide compelling proof of the defendant's active participation in a disturbing 
scheme to groom and sexually abuse minor girls'. 
The prosecutors said that it was 'curious' that Maxwell claimed to have access to millions 
of dollars had not offered 'a single dime' as collateral for her bond. 
They claimed that Maxwell's finances were 'completely opaque' and she had not even 
indicated which properties she would use for her bond. 
Some of the co-signers are 'themselves so wealthy that it would be no financial burden 
whatsoever' if they lost their $5 million by Maxwell skipping bail, the document states. 
Epstein's victims have long demanded Maxwell's arrest and lawyers for them say that a 
slew of new accusers have come forward since she was apprehended. 
Prosecutors will likely be looking to do a plea deal with Maxwell to lighten some of the six 
charges against her, two of which are perjury for allegedly lying during depositions. 
They will be questioning her about powerful men in Epstein's orbit including Bill Clinton 
with whom she flew on Epstein's private jet, called the 'Lolita Express', on a tour of Africa 
in 2002. 
Maxwell was also good friends with Prince Andrew and one of Epstein's victims, 
ims she was loaned out to the Duke three times for sex when she was 17. 
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Ghislaine Maxwell's attack-the-victim strategy may 
backfire 
bnnbloomberg.cakThislaine-maxwell•may-Olay-the-yictim-card-in-trial-defense-1.1465631 
July 15, 2020 
Ghislaine Maxwell Photographer: Laura Cavanaugh/Getty Images , Photographer: Laura 
Cavanaugh/Getty Images 
The bail hearing for Ghislaine Maxwell ended with a judge ruling that she must spend the 
next year behind bars awaiting trial on sex-trafficking charges tied to her former boyfriend 
Jeffrey Epstein. But it also offered hints at her defense strategy. 
During the two-hour video-conference hearing Tuesday, Maxwell's lawyers questioned the 
credibility of her accusers as well as the strength of the government's case. 
While the arguments were designed to win bail, they'll likely be the same ones used at the 
58-year-old's trial, which is scheduled to start next July. The federal charges stem from 
events that are more than two decades old, Maxwell's lawyer, Mark Cohen, said, noting 
that the government doesn't have "tapes or video" or other such evidence to support the 
allegations. 
"Absolutely, the defense is telegraphing where they're going," said David Weinstein, a 
former federal prosecutor who listened in on Maxwell's hearing. "While the defense isn't 
putting all of their cards on the table, they showed they're going to argue that she was as 
113 
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