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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
s "highly unlikely" that the French government would refuse to extradite Ms. Maxwell (Def. Mem., Ex. V at 2), the government attaches a letter from the French Ministry of Justice ("MOJ") that references neither Mr. Julie's report nor Ms. Maxwell, but states generally that the French Code of Criminal Procedure "absolutely pro
ant presents a risk of flight.' English, 629 F.3d at 319 (quoting Mercedes, 254 F.3d at 436); see also United States v. Manly., 782 F.2d 1141, 1144 (2d Cir. 1986) ("The government retains the burden of persuasion [in a presumption case]."). Even when "a defendant has met his burden of production," howev
Page: EFTA00013310 →r country. See Def. Mot., Exs. T, U, V. As the Government points out in its brief, however, the legal weight of the waivers is, at best, contested. The French Ministry of Justice, for instance, indicated in a letter submitted in conjunction to the Government's opposition that the French Code of Criminal Procedure "absolutely
Page: EFTA00013317 →y, the Defendant's argument that private security guards could ensure her appearance at future proceedings runs afoul of the Bail Reform Act, which the Second Circuit has held "does not permit a two-tiered bail system in which defendants of lesser means are detained pending trial while wealthy defendants are rele
Page: EFTA00013325 →ts that the Court should not consider the present bail motion because appeal of denial of the Second Bail Motion, not yet briefed, is pending before the Second Circuit. (Dkt. 165 at 2-3). It is ironic that the government takes this position given that it created this problem by opposing Ms. Maxwell's request for an
Page: EFTA00031920 →e de droll penal et de procedure penale Extradition Pa. - Conditions de fond de l'estradition Delphine Brach-Thiel-October 2t I 8„f59). 18. Third, the French Ministry of Justice's interpretation is contradicted by precedents and case law 19. The French Ministry of Justice's interpretation finds no support in case law, as no
Page: EFTA00031933 →Entities connected to both Second Circuit and the French Ministry of Justice

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONthe Southern District
LOCATION
Michael Cohen
PERSONJeffrey Pagliuca
PERSON
Southern District of New York
ORGANIZATION
New York
LOCATION
Denver
LOCATIONFBI
ORGANIZATIONLaura Menninger
PERSONCohen & Gresser LLP
ORGANIZATIONBobbi C. Sternheim
PERSON
United Kingdom
LOCATIONMark S. Cohen
PERSON
Bernie Madoff
PERSON
Brady
PERSONBoustani
PERSON
Alfredo Rodriguez
PERSONKarni
PERSON