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gnized as an indication of the defendant's intent not to flee. See, e.g., United States v. Khashoggi, 717 F. Supp. 1048, 1052 (S.D.N.Y. 1989) (Judge Keenan found defendant's extradition appeal waiver "manifests an intention to remain here and face the charges against him"). In response to the governme
Her Arrest 18 1. Ms. Maxwell Was Trying to Protect Herself from a Media Frenzy and from Physical Threats 18 2. Ms. Maxwell's Counsel Was in Regular Contact with the Government Prior to Her Arrest 22 3. Ms. Maxwell Did Not Try to Avoid Arrest, Nor Was She "Good At" Hiding 23 D. Ms. Maxwell Has Wai
gnized as an indication of the defendant's intent not to flee. See, e.g., United States v. Khashoggi, 717 F. Supp. 1048, 1052 (S.D.N.Y. 1989) (Judge Keenan found defendant's extradition appeal waiver "manifests an intention to remain here and face the charges against him"). In response to the governme
Her Arrest 18 1. Ms. Maxwell Was Trying to Protect Herself from a Media Frenzy and from Physical Threats 18 2. Ms. Maxwell's Counsel Was in Regular Contact with the Government Prior to Her Arrest 22 3. Ms. Maxwell Did Not Try to Avoid Arrest, Nor Was She "Good At" Hiding 23 D. Ms. Maxwell Has Wai
gnized as an indication of the defendant's intent not to flee. See, e.g., United States v. Khashoggi, 717 F. Supp. 1048, 1052 (S.D.N.Y. 1989) (Judge Keenan found defendant's extradition appeal waiver "manifests an intention to remain here and face the charges against him"). In response to the governme
8 1. Ms. Maxwell Was Trying to Protect Herself and Her Family from a Media Frenzy and from Physical Threats 18 2. Ms. Maxwell's Counsel Was in Regular Contact with the Government Prior to Her Arrest 22 3. Ms. Maxwell Did Not Try to Avoid Arrest, Nor Was She "Good At" Hiding 23 D. Ms. Maxwell Has Wai
tions. Doesn't mean the government has carried its burden of showing there is no combination of conditions. In the Khashoggi case, written by Judge Keenan in 1989, this was a person of extraordinary wealth, way more than anything the government alleges that our client has, he was, according to the go
ent Before Her Arrest 18 1. Ms. Maxwell Was Trying to Protect Herself a Media Frenzy and from Physical Threats 2. Ms. Maxwell's Counsel Was in Regular Contact with the Government Prior to Her Arrest from 3. Ms. Maxwell Did Not Try to Avoid Arrest, Nor Was She "Good At" Hiding D. Ms. Maxwell Has Waive
Entities connected to both Keenan and Regular Contact

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
United States
LOCATION
Michael Cohen
PERSON
Stephen Hawking
PERSON
Vicky Ward
PERSONSecond Circuit
ORGANIZATIONCohen & Gresser LLP
ORGANIZATION
Harvey Weinstein
PERSONBoustani
PERSONMark S. Cohen
PERSONKhashoggi
PERSONJeffrey Pagliuca
PERSONthe Southern District
LOCATIONSalvagno
PERSON
New Hampshire
LOCATIONRaniere
PERSONPetrov
PERSONKarni
PERSON