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is case. (Gov. Mem. at 4-5.) This oversimplifies the governing standard. Although the severity of potential punishment is a relevant consideration, the Second Circuit "require[s] more than evidence of the commission of a serious crime and the fact of a potentially long sentence to support a finding of risk of fli
ends and professional colleagues who reside in this country. In sum, the United States has been Ms. Maxwell's home for decades. b. Ms. Maxwell Has Actively Litigated Civil Cases in this District and Has Not Left the United States Since Epstein's 2019 Arrest Ms. Maxwell has never once attempted to "hide" from the government
is case. (Gov. Mem. at 4-5.) This oversimplifies the governing standard. Although the severity of potential punishment is a relevant consideration, the Second Circuit "require[s] more than evidence of the commission of a serious crime and the fact of a potentially long sentence to support a finding of risk of fli
ends and professional colleagues who reside in this country. In sum, the United States has been Ms. Maxwell's home for decades. b. Ms. Maxwell Has Actively Litigated Civil Cases in this District and Has Not Left the United States Since Epstein's 2019 Arrest Ms. Maxwell has never once attempted to "hide" from the government
is case. (Gov. Mem. at 4-5.) This oversimplifies the governing standard. Although the severity of potential punishment is a relevant consideration, the Second Circuit "require[s] more than evidence of the commission of a serious crime and the fact of a potentially long sentence to support a finding of risk of fli
ends and professional colleagues who reside in this country. In sum, the United States has been Ms. Maxwell's home for decades. b. Ms. Maxwell Has Actively Litigated Civil Cases in this District and Has Not Left the United States Since Epstein's 2019 Arrest Ms. Maxwell has never once attempted to "hide" from the government
is case. (Gov. Mem. at 4-5.) This oversimplifies the governing standard. Although the severity of potential punishment is a relevant consideration, the Second Circuit "require[s] more than evidence of the commission of a serious crime and the fact of a potentially long sentence to support a finding of risk of fli
ends and professional colleagues who reside in this country. In sum, the United States has been Ms. Maxwell's home for decades. b. Ms. Maxwell Has Actively Litigated Civil Cases in this District and Has Not Left the United States Since Epstein's 2019 Arrest Ms. Maxwell has never once attempted to "hide" from the government
is case. (Gov. Mem. at 4-5.) This oversimplifies the governing standard. Although the severity of potential punishment is a relevant consideration, the Second Circuit "require[s] more than evidence of the commission of a serious crime and the fact of a potentially long sentence to support a finding of risk of fli
ends and professional colleagues who reside in this country. In sum, the United States has been Ms. Maxwell's home for decades. b. Ms. Maxwell Has Actively Litigated Civil Cases in this District and Has Not Left the United States Since Epstein's 2019 Arrest Ms. Maxwell has never once attempted to "hide" from the government
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
ends and professional colleagues who reside in this country. In sum, the United States has been Ms. Maxwell's home for decades. b. Ms. Maxwell Has Actively Litigated Civil Cases in this District and Has Not Left the United States Since Epstein's 2019Arrest Ms. Maxwell has never once attempted to "hide" from the government o
is case. (Gov. Mem. at 4-5.) This oversimplifies the governing standard. Although the severity of potential punishment is a relevant consideration, the Second Circuit "require[s] more than evidence of the commission of a serious crime and the fact of a potentially long sentence to support a finding of risk of fli
ends and professional colleagues who reside in this country. In sum, the United States has been Ms. Maxwell's home for decades. b. Ms. Maxwell Has Actively Litigated Civil Cases in this District and Has Not Left the United States Since Epstein's 2019 Arrest Ms. Maxwell has never once attempted to "hide" from the government
Entities connected to both Second Circuit and Actively Litigated Civil Cases

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONthe Southern District
LOCATION
Michael Cohen
PERSON
Southern District of New York
ORGANIZATIONJeffrey Pagliuca
PERSON
Michael Jackson
PERSON
Stephen Hawking
PERSON
Denver
LOCATION
Colorado
LOCATIONFederal Bureau of Prisons
ORGANIZATIONCohen & Gresser LLP
ORGANIZATION
Bernie Madoff
PERSONMark S. Cohen
PERSONBoustani
PERSON
The New York Times
ORGANIZATION
United Kingdom
LOCATIONKarni
PERSONMarc Dreier
PERSON