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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
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
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
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
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
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
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
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
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
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
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
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 Second Circuit and New York Region

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