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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
UNITED STATES OF AMERICA 
20 Cr. 330 (AJN) 
GHISLAINE MAXWELL, 
Defendant. 
x 
TILE GOVERNMENT'S REPLY MEMORANDUM 
IN FURTHER SUPPORT OF DETENTION 
The Government respecttblly 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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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. 
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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 I (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 
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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. 
U. 
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 identity 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 (Med Stales 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.")); Unbed Stales v. Mica), 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. 
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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 Bail 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: I i I a S5 million personal recognizance bond, co-signed by six financially responsible 
people, 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 CPS 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 
tenris 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 victimsM 
claims 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 
a, bnnbloombera.cakThislaine-maxwell•mav-olav-the-victim-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 
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much a victim of Epstein -- much in the same way as these girls were -- and that she didn't 
know what was going on behind closed doors." 
Cohen briefly took aim at 
one of Maxwell's accusers. He said she has sued 
Maxwell and is seeking a payout from a fund set up for Epstein's victims, Cohen said. 
Established in May, Epstein's victims can be compensated by the financier's estate, valued 
at more than US$600 million. 
That's a dangerous tactic that might backfire at trial, said David Boies, who represents 
and several other women who say they were sexually abused by Epstein and 
Maxwell. 
It's "a tone-deaf argument" that cost Maxwell her credibility, said Boies, who listened to the 
hearing remotely. 
"To mount a 'blame the victim' defense, particularly in today's world and trying to blame 
these girls for what happened is so contrary to the evidence, is so contrary to people's 
normal sense of morality," Boies said. "I think that's just going to enrage a jury if she goes 
to trial -- which I would not do if I were representing her." 
Boies said he was confidennould 
stand up to cross-examination if there's a trial. 
who addressed the court by telephone, urged the judge not to grant Maxwell bail, 
calling her a "sexual predator who groomed and abused me." Maxwell "lied under oath and 
tormented her survivors," 
said. 
Boies said that 
Maxwell. 
was a 16-year-old who "wanted to go to college" when she met 
"Maxwell and Epstein tel
 and her mother 'we're having a group of hi 
school 
students to this ranch to help them get into college,"' Boies said. "But when 
gets 
there, there are no high school students, all these claims are fraudulent and she's in this 
isolated place in New Mexico." 
Remote Hearing 
Because of the pandemic, Maxwell's hearing was held remotely with press and the public 
permitted to hear arguments over the phone. About 6o members of the press were allowed 
to watch the proceeding on monitors in a jury room in the Manhattan courthouse, with the 
judge, lawyers and Maxwell all in different locations. 
Prosecutors also offered detail on their evidence, saying they have travel records, 
photographs and other documents that will support the charges. 
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Along witl
remarks, Assistant U.S. Attorney 
read from a letter 
written by another of Maxwell's alleged victims, who asked to be identified only as Jane 
Doe. It's possible that the woman may testify at the trial as well. 
"Without Ghislaine Maxwell, Jeffrey Epstein could not have done what he did; she egged 
him on," the woman said in the letter. She called Maxwell "a monster." 
The judge scheduled the trial for July 12. The defense must file its pretrial motions by Dec. 
21. 
--With assistance from Bob Van Voris. 
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Ghislaine Maxwell's neighbours tried to make her leave 
town 
ID dailvmail.co.uk/news/article-8525759/Neighbors-Ghislaine•Maxwell-lover-tried•ostracize-couple-make-leave-
town.html 
July 16, 2020 
• Ghislaine Maxwell had been living with her tech CEO lover Scott Borgerson 
at his home in Manchester-by-the-Sea outside of Boston until last December 
• In February 2019 neighbors learned the quiet, well-dressed woman in their 
midst had been accused of procuring young girls for pedophile Jeffrey Epstein 
• 'They were absolutely appalled to learn who they were allowing to have the 
run of their property,' one resident exclusively told DailyMail.com 
• Neighbors tried to harass and 'ostracize' Maxwell into leaving, and make her 
and Borgerson 'feel they weren't welcome on Sharksmouth or in Manchester' 
• It led to a court case where Borgerson successfully fought the neighbors' 
decision to stop them from using paths and a beach near the home that were 
part of a 4o-acre estate with other homes 
• A judge only made his ruling on March ii this year, three months after 
Maxwell had left Sharksmouth for good, moving to her hideaway in Bradford, 
NH 
• Borgerson is believed to have met Maxwell six years ago through speaking 
engagements connected to ocean preservation 
• They were both pictured speaking at the Arctic Circle Assembly in Reykjavik, 
Iceland, in 2014 
Ghislaine Maxwell's neighbors were so disgusted when they discovered an accused sex 
trafficker was living among them that they tried to harass her into leaving, DailyMail.com 
has learned exclusively. 
It led to a court case where Maxwell's 14-years-younger lover Scott Borgerson successfully 
fought the neighbors' decision to prevent them from using paths and a beach near their 
Massachusetts oceanfront property, part of the 40-acre estate shared by other owners. 
But the decision was not handed down until after Maxwell, 58, had already left for her new 
life of seclusion in neighboring New Hampshire. 
The small-town dispute involving the woman who was among the most-wanted in America, 
all played out in quaint Manchester-by-the-Sea, a well-to-do town 30 miles north of Boston 
where Maxwell was holed up with wealthy tech CEO Borgerson. 
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But in February 2019 neighbors learned the quiet, well-dressed woman in their midst had 
been accused of procuring young girls for pedophile Jeffrey Epstein — and they decided to 
act. 
'They were absolutely appalled to learn who they were allowing to have the run of their 
property,' one resident told DailyMail.com. 
'The second they learned she was involved with Epstein they decided to try to limit how 
much they could use their land.' 
Ghislaine Maxwell and Scott Borgerson's 
neighbors were so disgusted when they 
discovered an accused sex trafficker was 
living among them that they tried to harass 
her into leaving. Borgerson is believed to 
have met Maxwell six years ago through 
speaking engagements connected to ocean 
preservation, a subject on which they share 
a passion. They were both pictured speaking 
at the Arctic Circle Assembly in Reykjavik, 
Iceland, in 2014 (left and right) 
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k.C. Arctic Circle Sec retariatNimeo 
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It led to a court case where Maxwell's lover Scott Borgerson successfully fought the 
neighbors' decision to prevent them from using paths and a beach near their 
Massachusetts oceanfront property. Borgerson, 44, bought the Phippin House (pictured), a 
7-bedroom property, for $2.4M in June 24)16, using a limited liability company called 
Tidewood 
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