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ted States v. English, 629 F.3d 311, 319 (2d Cir. 2011) (quotation omitted). This rebuttable presumption can be readily satisfied, United States v. Conway, No. 4-11-70756 MAG (DMR), 2011 WL 3421321, at *2 (N.D. Cal. Aug. 3, 2011), and "[a]ny evidence favorable to a defendant that comes within a catego
. Carrillo-Villa, 20-MJ-3073 (SLC) 8 United States v. Chandler, 19-CR-867 (PAC), 2020 WL 1528120 (S.D.N.Y. Mar. 31, 2020) 8, 9 United States v. Conway, No. 4-11-70756 MAG(DMR), 2011 WL 3421321 (N.D. Cal. Aug. 3,2011) 10, 18 United States v. Crowell, No. 06-CR-291E(F), 2006 WL 3541736 (W.D.N.Y.
tics Demonstrate That She Is Not a Flight Risk a. Ms. Maxwell Has No Prior Criminal Record, and Has Significant Ties to the United States and the New York Region Ms. Maxwell's history and characteristics do not "strongly support detention," as the government contends (Gov. Mem. at 6), but instead demonstrate
ted States v. English, 629 F.3d 311, 319 (2d Cir. 2011) (quotation omitted). This rebuttable presumption can be readily satisfied, United States v. Conway, No. 4-11-70756 MAG (DMR), 2011 WL 3421321, at *2 (N.D. Cal. Aug. 3, 2011), and "[a]ny evidence favorable to a defendant that comes within a catego
. Carrillo-Villa, 20-MJ-3073 (SLC) 8 United States v. Chandler, 19-CR-867 (PAC), 2020 WL 1528120 (S.D.N.Y. Mar. 31, 2020) 8, 9 United States v. Conway, No. 4-11-70756 MAG(DMR), 2011 WL 3421321 (N.D. Cal. Aug. 3,2011) 10, 18 United States v. Crowell, No. 06-CR-291E(F), 2006 WL 3541736 (W.D.N.Y.
tics Demonstrate That She Is Not a Flight Risk a. Ms. Maxwell Has No Prior Criminal Record, and Has Significant Ties to the United States and the New York Region Ms. Maxwell's history and characteristics do not "strongly support detention," as the government contends (Gov. Mem. at 6), but instead demonstrate
ted States v. English, 629 F.3d 311, 319 (2d Cir. 2011) (quotation omitted). This rebuttable presumption can be readily satisfied, United States v. Conway, No. 4-11-70756 MAG (DMR), 2011 WL 3421321, at *2 (N.D. Cal. Aug. 3, 2011), and "[a]ny evidence favorable to a defendant that comes within a catego
. Carrillo-Villa, 20-MJ-3073 (SLC) 8 United States v. Chandler, 19-CR-867 (PAC), 2020 WL 1528120 (S.D.N.Y. Mar. 31, 2020) 8, 9 United States v. Conway, No. 4-11-70756 MAG(DMR), 2011 WL 3421321 (N.D. Cal. Aug. 3,2011) 10, 18 United States v. Crowell, No. 06-CR-291E(F), 2006 WL 3541736 (W.D.N.Y.
tics Demonstrate That She Is Not a Flight Risk a. Ms. Maxwell Has No Prior Criminal Record, and Has Significant Ties to the United States and the New York Region Ms. Maxwell's history and characteristics do not "strongly support detention," as the government contends (Gov. Mem. at 6), but instead demonstrate
ted States v. English, 629 F.3d 311, 319 (2d Cir. 2011) (quotation omitted). This rebuttable presumption can be readily satisfied, United States v. Conway, No. 4-11-70756 MAG (DMR), 2011 WL 3421321, at *2 (N.D. Cal. Aug. 3, 2011), and "[a]ny evidence favorable to a defendant that comes within a catego
. Carrillo-Villa, 20-MJ-3073 (SLC) 8 United States v. Chandler, 19-CR-867 (PAC), 2020 WL 1528120 (S.D.N.Y. Mar. 31, 2020) 8, 9 United States v. Conway, No. 4-11-70756 MAG(DMR), 2011 WL 3421321 (N.D. Cal. Aug. 3,2011) 10, 18 United States v. Crowell, No. 06-CR-291E(F), 2006 WL 3541736 (W.D.N.Y.
tics Demonstrate That She Is Not a Flight Risk a. Ms. Maxwell Has No Prior Criminal Record, and Has Significant Ties to the United States and the New York Region Ms. Maxwell's history and characteristics do not "strongly support detention," as the government contends (Gov. Mem. at 6), but instead demonstrate
ted States v. English, 629 F.3d 311, 319 (2d Cir. 2011) (quotation omitted). This rebuttable presumption can be readily satisfied, United States v. Conway, No. 4-11-70756 MAG (DMR), 2011 WL 3421321, at *2 (N.D. Cal. Aug. 3, 2011), and "[a]ny evidence favorable to a defendant that comes within a catego
. Carrillo-Villa, 20-MJ-3073 (SLC) 8 United States v. Chandler, 19-CR-867 (PAC), 2020 WL 1528120 (S.D.N.Y. Mar. 31, 2020) 8, 9 United States v. Conway, No. 4-11-70756 MAG(DMR), 2011 WL 3421321 (N.D. Cal. Aug. 3,2011) 10, 18 United States v. Crowell, No. 06-CR-291E(F), 2006 WL 3541736 (W.D.N.Y.
tics Demonstrate That She Is Not a Flight Risk a. Ms. Maxwell Has No Prior Criminal Record, and Has Significant Ties to the United States and the New York Region Ms. Maxwell's history and characteristics do not "strongly support detention," as the government contends (Gov. Mem. at 6), but instead demonstrate
ted States v. English, 629 F.3d 311, 319 (2d Cir. 2011) (quotation omitted). This rebuttable presumption can be readily satisfied, United States v. Conway, No. 4-11-70756 MAG (DMR), 2011 WL 3421321, at *2 (N.D. Cal. Aug. 3, 2011), and "[a]ny evidence favorable to a defendant that comes within a catego
. Carrillo-Villa, 20-MJ-3073 (SLC) 8 United States v. Chandler, 19-CR-867 (PAC), 2020 WL 1528120 (S.D.N.Y. Mar. 31, 2020) 8, 9 United States v. Conway, No. 4-11-70756 MAG(DMR), 2011 WL 3421321 (N.D. Cal. Aug. 3,2011) 10, 18 United States v. Crowell, No. 06-CR-291E(F), 2006 WL 3541736 (W.D.N.Y.
tics Demonstrate That She Is Not a Flight Risk a. Ms. Maxwell Has No Prior Criminal Record, and Has Significant Ties to the United States and the New York Region Ms. Maxwell's history and characteristics do not "strongly support detention," as the government contends (Gov. Mem. at 6), but instead demonstrate
Entities connected to both Conway and New York Region

Jeffrey Epstein
PERSON
Stephen Hawking
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Ghislaine Maxwell
PERSON
United States
LOCATION
Michael Cohen
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Bernie Sanders
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Michael Jackson
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Colorado
LOCATION
Houston
LOCATIONthe Southern District
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Mattis
PERSONCourtney Wild
PERSONMarc Dreier
PERSONSecond Circuit
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Denver
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Bernie Madoff
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Hanson
PERSONKarni
PERSONFederal Bureau of Prisons
ORGANIZATION
European Union
ORGANIZATION