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ng United States v. Esposito, 309 F. Supp. 3d 24 (S.D.N.Y. 2018), United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009), and United States v. Madoff, 586 F. Supp. 2d 240 (S.D.N.Y. 2009), as "not on point and not persuasive," and distinguished the defendant for a number of reasons, including the
to granting bail. The proposed conditions ensure her presence at home in plain sight of (and the security guards), GPS- monitored, and under strict Pretrial supervision. D. Ms. Maxwell Has Waived Her Extradition Rights and Could Not Seek Refuge in the United Kingdom or France At the initial hearing, t
continue to need security guards to protect her upon release. Under the circumstances, if the Court requires it, the security guards could report to Pretrial Services.16 10 In United States v. Houston!, 932 F.3d 79 (2d Cir. 2019), the Second Circuit curtailed the circumstances under which a court can gra
Page: EFTA00018538 →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 →The Court is unpersuaded. 13 EFTA00013319 --- PAGE BREAK --- United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009), and United States v. Madoff 586 F. Supp. 2d 240 (S.D.N.Y. 2009)). The Court's concerns regarding the absence of any dependents, significant family ties, or employment in the
Page: EFTA00013320 →he evidence of a lack of candor is, if anything, stronger now than in July 2020, as it is clear to the Court that the Defendant's representations to Pretrial Services were woefully incomplete. That lack of candor raises significant concerns as to whether the Court has now been provided a full and accurat
Page: EFTA00013322 →Entities connected to both Bernie Madoff and Pretrial

Jeffrey Epstein
PERSON
George W. Bush
PERSONLeon Black
PERSON
Marc Rich
PERSON
Prince Andrew
PERSON
Barack Obama
PERSON
Michael Cohen
PERSON
Bill Clinton
PERSON
Denver
LOCATIONMartin Weinberg
PERSON
Hillary Clinton
PERSONSouthern District
LOCATION
Ghislaine Maxwell
PERSON
United States
LOCATIONthe Southern District
LOCATIONFederal Bureau of Prisons
ORGANIZATIONSecond Circuit
ORGANIZATION
Department of Justice
ORGANIZATION
New York
LOCATION
Metropolitan Correctional Center
ORGANIZATION