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me, your Honor; and most recently it appears that she spent the last year making concerted efforts to conceal her whereabouts whilst moving around New England, most recently to New Hampshire, which I will discuss momentarily with respect to that particular THE COURT: : -- property. THE COURT: there is
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 law of the statute, by its structure, favors release. The Supreme Court has and the Second Circuit has advised us that a very limited number of people should be detained prior to trial because of the statute's structure, and the government nowher
intent was exactly the opposite. As her spouse's letter makes clear, after spending a few months away from Massachusetts, Ms. Maxwell moved back to New England so that she could be close to her family, but also to be within driving distance of the prosecutors in New York in case they wished to speak to her.
tin foil, we explained to the Court at the initial bail hearing that Ms. Maxwell took this step to prevent the press from accessing her phone after the Second Circuit inadvertently unsealed certain court records with the phone number unredacted. (Tr. 55-56). Having now reviewed the discovery produced by the govern
ereafter, the defendant — who had previously made many public appearances — stopped appearing in public entirely, instead hiding out in locations in New England. Moreover, it appears that she made intentional efforts to avoid detection, including moving locations at least twice, switching her primary phone
risonment for turning off a light in a lighthouse to expose a ship to danger). Even if there were evidence to back up the four anonymous accusers, the Second Circuit "require[s] more than evidence of the commission of a serious crime and the fact of a potential long sentence to support a finding of risk of fligh
me, your Honor; and most recently it appears that she spent the last year making concerted efforts to conceal her whereabouts whilst moving around New England, most recently to New Hampshire, which I will discuss momentarily with respect to that particular THE COURT: : -- property. THE COURT: there is
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 law of the statute, by its structure, favors release. The Supreme Court has and the Second Circuit has advised us that a very limited number of people should be detained prior to trial because of the statute's structure, and the government nowher
a preponderance of the evidence. See, e.g., United States v. Patriarca, 948 F.2d 789, 793 (1st Cir. 1991); United States v. Jackson, 823 F.2d 4, 5 (2d Cir. 1987); United States v. Chimurenga, 760 F.2d 400, 405 (2d Cir. 1985). A finding of dangerousness must be supported by clear and convincing evidence
Page: EFTA00018508 →ereafter, the defendant — who had previously made many public appearances - stopped appearing in public entirely, instead hiding out in locations in New England. Moreover, it appears that she made intentional efforts to avoid detection, including moving locations at least twice, switching her primary phone
Page: EFTA00018513 →Entities connected to both New England and Second Circuit

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSONthe Southern District
LOCATION
Department of Justice
ORGANIZATION
Julie K. Brown
PERSON
Michael Cohen
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Michael Jackson
PERSON
George W. Bush
PERSON
Supreme Court
ORGANIZATION
Southern District of New York
ORGANIZATION
New York
LOCATION
Stephen Hawking
PERSON
Donald Trump
PERSONJeffrey Pagliuca
PERSON
Virginia Giuffre
PERSON
David Boies
PERSON