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09) (Marc Dreier, accused of "colossal criminality" and alleged to be a "high flight risk," granted release subject to conditions); United States v. Madoff, 586 F. Supp. 2d 240, 243 (S.D.N.Y. 2009) (Bernie Madoff, charged with "largest Ponzi scheme ever and alleged to be a "serious risk of flight," gra
and alleged to be a "high flight risk," granted release subject to conditions); United States v. Madoff, 586 F. Supp. 2d 240, 243 (S.D.N.Y. 2009) (Bernie Madoff, charged with "largest Ponzi scheme ever and alleged to be a "serious risk of flight," granted release subject to conditions). not have Ms. Maxwell
21321 (N.D. Cal. Aug. 3,2011) 10, 18 United States v. Crowell, No. 06-CR-291E(F), 2006 WL 3541736 (W.D.N.Y. Dec. 7, 2006) 11 United States v. Deutsch, No. 18-CR-502 (FB), 2020 WL 3577398 (E.D.N.Y. July 1, 2020) 11, 18 United States v. DiGiacomo, 746 F. Supp. 1176 (D. Mass. 1990) 14 United
d that defendants rebutted the presumption and imposed appropriately strict bail conditions in cases involving alleged offenses against minors. See Deutsch, 2020 WL 3577398, at *5-6; United States v. Veres, No. 3:20-CR-18-J-32JBT, 2020 WL 1042051, at *3-4 (M.D. Fla. Mar. 4, 2020); Conway, 2011 WL 34213
hat cannot be addressed by any bail conditions. English, 629 F.3d at 319 (citation and internal quotation marks omitted); see also United States v. Deutsch, No. I 8-CR-502 (FB), 2020 WL 3577398, at *5 (E.D.N.Y. July I, 2020). And regardless of the presence of the presumption or the nature of the charges
and alleged to be a "high flight risk," granted release subject to conditions); United States v. Madoff, 586 F. Supp. 2d 240, 243 (S.D.N.Y. 2009) (Bernie Madoff, charged with "largest Ponzi scheme ever and alleged to be a "serious risk of flight," granted release subject to conditions). not have Ms. Maxwell
09) (Marc Dreier, accused of "colossal criminality" and alleged to be a "high flight risk," granted release subject to conditions); United States v. Madoff, 586 F. Supp. 2d 240, 243 (S.D.N.Y. 2009) (Bernie Madoff, charged with "largest Ponzi scheme ever and alleged to be a "serious risk of flight," gra
21321 (N.D. Cal. Aug. 3,2011) 10, 18 United States v. Crowell, No. 06-CR-291E(F), 2006 WL 3541736 (W.D.N.Y. Dec. 7, 2006) 11 United States v. Deutsch, No. 18-CR-502 (FB), 2020 WL 3577398 (E.D.N.Y. July 1, 2020) 11, 18 United States v. DiGiacomo, 746 F. Supp. 1176 (D. Mass. 1990) 14 United
d that defendants rebutted the presumption and imposed appropriately strict bail conditions in cases involving alleged offenses against minors. See Deutsch, 2020 WL 3577398, at *5-6; United States v. Veres, No. 3:20-CR-18-J-32JBT, 2020 WL 1042051, at *3-4 (M.D. Fla. Mar. 4, 2020); Conway, 2011 WL 34213
hat cannot be addressed by any bail conditions. English, 629 F.3d at 319 (citation and internal quotation marks omitted); see also United States v. Deutsch, No. I 8-CR-502 (FB), 2020 WL 3577398, at *5 (E.D.N.Y. July I, 2020). And regardless of the presence of the presumption or the nature of the charges
and alleged to be a "high flight risk," granted release subject to conditions); United States v. Madoff, 586 F. Supp. 2d 240, 243 (S.D.N.Y. 2009) (Bernie Madoff, charged with "largest Ponzi scheme ever and alleged to be a "serious risk of flight," granted release subject to conditions). not have Ms. Maxwell
09) (Marc Dreier, accused of "colossal criminality" and alleged to be a "high flight risk," granted release subject to conditions); United States v. Madoff, 586 F. Supp. 2d 240, 243 (S.D.N.Y. 2009) (Bernie Madoff, charged with "largest Ponzi scheme ever and alleged to be a "serious risk of flight," gra
21321 (N.D. Cal. Aug. 3,2011) 10, 18 United States v. Crowell, No. 06-CR-291E(F), 2006 WL 3541736 (W.D.N.Y. Dec. 7, 2006) 11 United States v. Deutsch, No. 18-CR-502 (FB), 2020 WL 3577398 (E.D.N.Y. July 1, 2020) 11, 18 United States v. DiGiacomo, 746 F. Supp. 1176 (D. Mass. 1990) 14 United
d that defendants rebutted the presumption and imposed appropriately strict bail conditions in cases involving alleged offenses against minors. See Deutsch, 2020 WL 3577398, at *5-6; United States v. Veres, No. 3:20-CR-18-J-32JBT, 2020 WL 1042051, at *3-4 (M.D. Fla. Mar. 4, 2020); Conway, 2011 WL 34213
hat cannot be addressed by any bail conditions. English, 629 F.3d at 319 (citation and internal quotation marks omitted); see also United States v. Deutsch, No. I 8-CR-502 (FB), 2020 WL 3577398, at *5 (E.D.N.Y. July I, 2020). And regardless of the presence of the presumption or the nature of the charges
09) (Marc Dreier, accused of "colossal criminality" and alleged to be a "high flight risk," granted release subject to conditions); United States v. Madoff, 586 F. Supp. 2d 240, 243 (S.D.N.Y. 2009) (Bernie Madoff, charged with "largest Ponzi scheme ever and alleged to be a "serious risk of flight," gra
and alleged to be a "high flight risk," granted release subject to conditions); United States v. Madoff, 586 F. Supp. 2d 240, 243 (S.D.N.Y. 2009) (Bernie Madoff, charged with "largest Ponzi scheme ever and alleged to be a "serious risk of flight," granted release subject to conditions). not have Ms. Maxwell
21321 (N.D. Cal. Aug. 3,2011) 10, 18 United States v. Crowell, No. 06-CR-291E(F), 2006 WL 3541736 (W.D.N.Y. Dec. 7, 2006) 11 United States v. Deutsch, No. 18-CR-502 (FB), 2020 WL 3577398 (E.D.N.Y. July 1, 2020) 11, 18 United States v. DiGiacomo, 746 F. Supp. 1176 (D. Mass. 1990) 14 United
d that defendants rebutted the presumption and imposed appropriately strict bail conditions in cases involving alleged offenses against minors. See Deutsch, 2020 WL 3577398, at *5-6; United States v. Veres, No. 3:20-CR-18-J-32JBT, 2020 WL 1042051, at *3-4 (M.D. Fla. Mar. 4, 2020); Conway, 2011 WL 34213
hat cannot be addressed by any bail conditions. English, 629 F.3d at 319 (citation and internal quotation marks omitted); see also United States v. Deutsch, No. I 8-CR-502 (FB), 2020 WL 3577398, at *5 (E.D.N.Y. July I, 2020). And regardless of the presence of the presumption or the nature of the charges
09) (Marc Dreier, accused of "colossal criminality" and alleged to be a "high flight risk," granted release subject to conditions); United States v. Madoff, 586 F. Supp. 2d 240, 243 (S.D.N.Y. 2009) (Bernie Madoff, charged with "largest Ponzi scheme ever and alleged to be a "serious risk of flight," gra
and alleged to be a "high flight risk," granted release subject to conditions); United States v. Madoff, 586 F. Supp. 2d 240, 243 (S.D.N.Y. 2009) (Bernie Madoff, charged with "largest Ponzi scheme ever and alleged to be a "serious risk of flight," granted release subject to conditions). not have Ms. Maxwell
21321 (N.D. Cal. Aug. 3,2011) 10, 18 United States v. Crowell, No. 06-CR-291E(F), 2006 WL 3541736 (W.D.N.Y. Dec. 7, 2006) 11 United States v. Deutsch, No. 18-CR-502 (FB), 2020 WL 3577398 (E.D.N.Y. July 1, 2020) 11, 18 United States v. DiGiacomo, 746 F. Supp. 1176 (D. Mass. 1990) 14 United
d that defendants rebutted the presumption and imposed appropriately strict bail conditions in cases involving alleged offenses against minors. See Deutsch, 2020 WL 3577398, at *5-6; United States v. Veres, No. 3:20-CR-18-J-32JBT, 2020 WL 1042051, at *3-4 (M.D. Fla. Mar. 4, 2020); Conway, 2011 WL 34213
hat cannot be addressed by any bail conditions. English, 629 F.3d at 319 (citation and internal quotation marks omitted); see also United States v. Deutsch, No. I 8-CR-502 (FB), 2020 WL 3577398, at *5 (E.D.N.Y. July I, 2020). And regardless of the presence of the presumption or the nature of the charges
d with similar or more serious offenses, many of whom have foreign ties, are routinely granted bail so that they can effectively prepare for trial. Bernie Madoff. Harvey Weinstein. Bill Cosby. John Gotti. Marc Dreier. Dominique Strauss- Kahn. Ali Sadr. Adnan Khashoggi. Mahender Sabhnani. The list goes on and
09) (Marc Dreier, accused of "colossal criminality" and alleged to be a "high flight risk," granted release subject to conditions); United States v. Madoff, 586 F. Supp. 2d 240, 243 (S.D.N.Y. 2009) (Bernie Madoff, charged with "largest Ponzi scheme ever" and alleged to be a "serious risk of flight," gr
d that defendants rebutted the presumption and imposed appropriately strict bail conditions in cases involving alleged offenses against minors. See Deutsch, 2020 WL 3577398, at *5-6; United States v. Veres, No. 3:20-CR-18-.1-32JBT, 2020 WL 1042051, at *34 (M.D. Fla. Mar. 4, 2020); Conway, 2011 WL 34213
421321 (N.D. Cal. Aug. 3, 2011) 10, 18 United States v. Crowell, No. 06-CR-291E(F), 2006 WL 3541736 (W.D.N.Y. Dec. 7, 2006) 1 I United States v. Deutsch, No. 18-CR-502 (FB), 2020 WL 3577398 (E.D.N.Y. July 1, 2020) II, 18 United States v. DiGiacomo, 746 F. Supp. 1176 (D. Mass. 1990) 14 United Sta
hat cannot be addressed by any bail conditions. English, 629 F.3d at 319 (citation and internal quotation marks omitted); see also United States v. Deutsch, No. 18-CR-502 (FB), 2020 WL 3577398, at *5 (E.D.N.Y. July 1, 2020). And regardless of the presence of the presumption or the nature of the charges
and alleged to be a "high flight risk," granted release subject to conditions); United States v. Madoff, 586 F. Supp. 2d 240, 243 (S.D.N.Y. 2009) (Bernie Madoff, charged with "largest Ponzi scheme ever and alleged to be a "serious risk of flight," granted release subject to conditions). not have Ms. Maxwell
09) (Marc Dreier, accused of "colossal criminality" and alleged to be a "high flight risk," granted release subject to conditions); United States v. Madoff, 586 F. Supp. 2d 240, 243 (S.D.N.Y. 2009) (Bernie Madoff, charged with "largest Ponzi scheme ever and alleged to be a "serious risk of flight," gra
21321 (N.D. Cal. Aug. 3,2011) 10, 18 United States v. Crowell, No. 06-CR-291E(F), 2006 WL 3541736 (W.D.N.Y. Dec. 7, 2006) 11 United States v. Deutsch, No. 18-CR-502 (FB), 2020 WL 3577398 (E.D.N.Y. July 1, 2020) 11, 18 United States v. DiGiacomo, 746 F. Supp. 1176 (D. Mass. 1990) 14 United
d that defendants rebutted the presumption and imposed appropriately strict bail conditions in cases involving alleged offenses against minors. See Deutsch, 2020 WL 3577398, at *5-6; United States v. Veres, No. 3:20-CR-18-J-32JBT, 2020 WL 1042051, at *3-4 (M.D. Fla. Mar. 4, 2020); Conway, 2011 WL 34213
hat cannot be addressed by any bail conditions. English, 629 F.3d at 319 (citation and internal quotation marks omitted); see also United States v. Deutsch, No. I 8-CR-502 (FB), 2020 WL 3577398, at *5 (E.D.N.Y. July I, 2020). And regardless of the presence of the presumption or the nature of the charges
ry of the defendant. The government said -- THE COURT: Mr. Cohen, just before you move to that, the three cases that you cited -- Esposito, Dreier, Madoff - factually did any of those cases involve defendants with substantial international and foreign connections? MR. COHEN: No, I don't believe they
ars to have been based on the resources available to defendant, not foreign connections or experience and a record of hiding from being found. In Madoff, the defendant had already been released on a bail package agreed to by the parties for a considerable period of time before the government sought
hey all made appearances and appeared for trial. There are also cases from the context involving pornography or sex crime allegations, such as the Deutsch case coming from the Eastern District several years ago, the Conway case in the Northern District of California. Again, understanding those are th
ry of the defendant. The government said -- THE COURT: Mr. Cohen, just before you move to that, the three cases that you cited -- Esposito, Dreier, Madoff - factually did any of those cases involve defendants with substantial international and foreign connections? MR. COHEN: No, I don't believe they
ars to have been based on the resources available to defendant, not foreign connections or experience and a record of hiding from being found. In Madoff, the defendant had already been released on a bail package agreed to by the parties for a considerable period of time before the government sought
hey all made appearances and appeared for trial. There are also cases from the context involving pornography or sex crime allegations, such as the Deutsch case coming from the Eastern District several years ago, the Conway case in the Northern District of California. Again, understanding those are th
421321 (N.D. Cal. Aug. 3,2011) 10, 18 United States v. Crowell, No. 06-CR-29IE(F), 2006 WL 3541736 (W.D.N.Y. Dec. 7, 2006) 11 United States v Deutsch, No. 18-CR-502 (FB), 2020 WL 3577398 (E.D.N.Y. July 1, 2020) 11, 18 United States v. DiGiacomo, 746 F. Supp. 1176 (D. Mass. 1990) 14 United
Page: EFTA00018517 →d that defendants rebutted the presumption and imposed appropriately strict bail conditions in cases involving alleged offenses against minors. See Deutsch, 2020 WL 3577398, at *5-6; United States v. Veres, No. 3:20-CR-18-J-32JBT, 2020 WL 1042051, at *3-4 (M.D. Fla. Mar. 4, 2020); Conway, 2011 WL 34213
Page: EFTA00018536 →09) (Marc Dreier, accused of "colossal criminality" and alleged to be a "high flight risk," granted release subject to conditions); United States v. Madoff, 586 F. Supp. 2d 240, 243 (S.D.N.Y. 2009) (Bernie Madoff, charged with "largest Ponzi scheme ever and alleged to be a "serious risk of flight," gra
Page: EFTA00018540 →and alleged to be a "high flight risk," granted release subject to conditions); United States v. Madoff, 586 F. Supp. 2d 240, 243 (S.D.N.Y. 2009) (Bernie Madoff, charged with "largest Ponzi scheme ever and alleged to be a "serious risk of flight," granted release subject to conditions). not have Ms. Maxwell
Page: EFTA00018540 →Entities connected to both Bernie Madoff and Deutsch

Jeffrey Epstein
PERSON
Jared Kushner
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Julie K. Brown
PERSON
Marc Rich
PERSON
Justin Trudeau
PERSON
Prince Andrew
PERSON
Michael Cohen
PERSONLeon Black
PERSON
Colorado
LOCATION
Bill Clinton
PERSON
Barack Obama
PERSON
Denver
LOCATIONthe Securities and Exchange Commission
ORGANIZATIONMartin Weinberg
PERSON
Hillary Clinton
PERSON
Alexander Acosta
PERSON
Puerto Rico
LOCATION
Bear Stearns
ORGANIZATION