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favoring detention does not disappear entirely, but remains a factor to be considered among those weighed by the district court." United States v. Mattis, 963 F.3d 285, 290 91 (2d Cir. 2020). After a court has made an initial determination that no conditions of release can reasonably assure the appea
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
favoring detention does not disappear entirely, but remains a factor to be considered among those weighed by the district court." United States v. Mattis, 963 F.3d 285, 290-91 (2d Cir. 2020). After a court has made an initial determination that no conditions of release can reasonably assure the appea
Page: EFTA00013310 →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 →United States v. Karni, 298 F. Supp. 2d 129 (D.D.C. 2004) 16 United States v. Kashoggi, 717 F. Supp. 1048 (S.D.N.Y. 1989) 16 United States v. Mattis, No. 20-1713, 2020 WL 3536277 (2d Cir. June 30, 2020) 10 United States v. Moscaritolo, No. 10 Cr. 4 (JL), 2010 WL 309679 (D.N.H. Jan. 26, 2010)
Page: EFTA00018518 →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 →Entities connected to both Mattis and Pretrial

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSON
Michael Cohen
PERSONthe Southern District
LOCATION
Barack Obama
PERSON
Stephen Hawking
PERSON
United Kingdom
LOCATIONFederal Bureau of Prisons
ORGANIZATIONLeon Black
PERSONBoustani
PERSON
George W. Bush
PERSONKarni
PERSONSecond Circuit
ORGANIZATION
Bernie Madoff
PERSONMarc Dreier
PERSONJeffrey Pagliuca
PERSONPark Row
LOCATION
Bill Clinton
PERSON
Marc Rich
PERSON