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a private security company could conceivably be considered as a bail condition. See United States v. Boustani, 932 F.3d 79, 82 (2d Cir. 2019). The Second Circuit has squarely held that "the Bail Reform Act does not permit a two-tiered bail system in which defendants of lesser means are detained pending trial
orgiou, No. 08-1220-M, 2008 WL 4306750 (E.D. Pa. Sept. 22, 2008) 15 United States v. Karni, 298 F. Supp. 2d 129 (D.D.C. 2004) 15 United States v. Kazeem, No. 15 Cr. 172, 2015 WL 4645357 (D. Or. Aug. 3, 2015) 15 United States v. Khashoggi, 717 F. Supp. 1048 (S.D.N.Y. 1989) IS, 28 United States v. M
a private security company could conceivably be considered as a bail condition. See United States v. Boustani, 932 F.3d 79, 82 (2d Cir. 2019). The Second Circuit has squarely held that "the Bail Reform Act does not permit a two-tiered bail system in which defendants of lesser means are detained pending trial
t] has fled the Court's jurisdiction."); United States v. Morrison, No. 16-MR-118, 2016 WL 7421924, at *4 (W.D.N.Y. Dec. 23, 2016); United States v. Kazeem, No. 15 Cr. 172, 2015 WL 4645357, at *3 (D. Or. Aug. 3, 2015); United States v. Young, Nos. 12 Cr. 502, 12 Cr. 645, 2013 WL 12131300, at *7 (D. Uta
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
orgiou, No. 08-1220-M, 2008 WL 4306750 (E.D. Pa. Sept. 22, 2008) 15 United States v. Karni, 298 F. Supp. 2d 129 (D.D.C. 2004) 15 United States v. Kazeem, No. 15 Cr. 172, 2015 WL 4645357 (D. Or. Aug. 3, 2015) 15 United States v. Khashoggi, 717 F. Supp. 1048 (S.D.N.Y. 1989) 15, 28 United States v. M
ed provides the motive for him do so and is another significant factor in assessing the risk of flight. See United States v. Jackson, 823 F.2d 4, 7 (2d Cir. 1987). So too is the strength of the evidence, detailed above and in the Government's Detention Memo. Indeed, that evidence, already robust less th
Page: EFTA00015536 →to which he chose to flee). See, e.g., United States v. Morrison, No. 16-MR-118, 2016 WL 7421924, at *4 (W.D.N.Y. Dec. 23, 2016); United States v. Kazeem, No. 15 Cr. 172, 2015 WL 4645357, at *3 (D. Or. Aug. 3, 2015); United States v. Young, Nos. 12 Cr. 502, 12 Cr. 645, 2013 WL 12131300, at *7 (D. Utah
Page: EFTA00015538 →n to dozens of victims who were abused in Florida. 2 While beyond the scope of a bail hearing, as discussed further below, it is well-established in the Second Circuit that absent an express provision to the contrary in the agreement, one District is not bound by the terms of an agreement entered into between a def
Page: EFTA00015549 →and effectively meaningless. See, e.g., United States v. Morrison, No. 16-MR-118, 2016 WL 7421924, at *4 (W.D.N.Y. Dec. 23, 2016); United States v. Kazeem, No. 15 Cr. 172, 2015 WL 4645357, at *3 (D. Or. Aug. 3, 2015); United States v. Young, Nos. 12 Cr. 502, 12 Cr. 645, 2013 WL 12131300, at *7 (D. Uta
Page: EFTA00030252 →) (Bianco, J.) (collecting cases). The Second Circuit has never directly addressed this issue. See United States v. Sabhnani, 493 F.3d 63, 78 n.18 (2d Cir. 2007) ("The government has not argued and, therefore, EFTA00030252 --- PAGE BREAK --- Honorable Richard M. Berman United States District Judge
Page: EFTA00030253 →to which he chose to flee). See, e.g., United States v. Morrison, No. 16-MR-118, 2016 WL 7421924, at *4 (W.D.N.Y. Dec. 23, 2016); United States v. Kazeem, No. 15 Cr. 172, 2015 WL 4645357, at *3 (D. Or. Aug. 3, 2015); United States v. Young, Nos. 12 Cr. 502, 12 Cr. 645, 2013 WL 12131300, at *7 (D. Utah
Page: EFTA00028791 →elaborately replicate a detention facility without the confidence of security such a facility instills."' United States v. Orena, 986 F.2d 628, 632 (2d Cir. 1993) (quoting United States v. Gotti, 776 F. Supp. 666, 672 (E.D.N.Y. 1991) (rejecting private jail proposal)); see also Valerio, 9 F. Supp. 3d at
Page: EFTA00028792 →Entities connected to both Second Circuit and Kazeem

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONthe Southern District
LOCATION
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Julie K. Brown
PERSON
Michael Cohen
PERSON
Southern District of New York
ORGANIZATIONMartin Weinberg
PERSON
Michael Jackson
PERSON
New York
LOCATIONFBI
ORGANIZATION
Harry Reid
PERSON
Reid Weingarten
PERSON
New York State
LOCATION
Anderson
PERSONDistrict Court for the Southern District of New York
ORGANIZATION
Geoffrey S. Berman
PERSONBoustani
PERSON