Document 182

Case 1:20-cr-00330-PAE Document 182 Filed 03/26/21 Page 1 of 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, v. Case No.: 20-CR-330-AJN MOTION FOR ADMISSION PRO HAC VICE GHISLAINE MAXWELL Defendant. Pursuant to Rule 1.3 of the Local Rules of the United States Courts for the Southern and Eastern Districts of New York, Sigrid S. McCawley, hereby move this Court for an Order for Admission to practice Pro Hac Vice to appear as counsel for Boies Schiller Flexner LLP and the victims it represents in the above-captioned action. I am in good standing in the bars of the State of Florida and Washington, D.C. and there are no pending disciplinary proceedings against me in any state or federal court. I have never been convicted of a felony. I have never been censured, suspended, disbarred or denied admission or readmission by any court. I have attached the affidavit pursuant to Local Rule 1.3. Dated: March 26, 2021 Respectfully Submitted, /s/ Sigrid S. McCawley Sigrid S. McCawley Boies Schiller Flexner LLP 401 E. Las Olas Boulevard, Suite 1200 Fort Lauderdale, FL 33301 Tel: (954) 356-0011 Fax: (954) 356 0022 Email: smccawley@bsfllp.com Attorney for Intervenor Boies Schiller Flexner LLP and the victims it represents DOJ-OGR-00002806 --- PAGE BREAK --- Case 1:20-cr-03309 Document 182 Filed 07/30/21 Page 29 of 290 PRELIMINARY STATEMENT Ghislaine Maxwell respectfully submits this Memorandum in Opposition to the government's July 2, 2020 Memorandum in Support of Detention ("Gov. Mem."). It is difficult to recall a recent case that has garnered more public attention than the government's prosecution of Jeffrey Epstein ("Epstein"). In July 2019, Epstein was indicted for offenses relating to sexual misconduct, amid overwhelming media attention focused on the nature of the charges and Epstein's wealth and lifestyle. On August 10, 2019, Epstein died in federal custody, and the media focus quickly shifted to our client—wrongly trying to substitute her for Epstein—even though she'd had no contact with Epstein for more than a decade, had never been charged with a crime or been found liable in any civil litigation, and has always denied any allegations of claimed misconduct. Many of these stories and online posts were threatening and harassing to our client and those close to her. But sometimes the simplest point is the most critical one: Ghislaine Maxwell is not Jeffrey Epstein. She was not named in the government's indictment of Epstein in 2019, despite the fact that the government has been investigating this case for years. Instead, the current indictment is based on allegations of conduct that allegedly occurred roughly twenty-five years ago. Ms. Maxwell vigorously denies the charges, intends to fight them, and is entitled to the presumption of innocence. Far from "hiding," she has lived in the United States since 1991, has litigated civil cases arising from her supposed ties to Epstein, and has not left the country even once since Epstein's arrest a year ago, even though she was aware of the pending, and highly publicized, criminal investigation. She should be 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 as decisions of this Court, Ms. Maxwell should be released on bail, subject to the strict conditions proposed below. DOJ-OGR-00019879