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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
CONCLUSION 38 ii EFTA00065718 TABLE OF AUTHORITIES Page(s) Cases United States v. Boustani, 932 F.3d 79 (2d Cir. 2019) 3 United States v. Bradshaw, No. 0040033-04-DES, 2000 WL 1371517 (D. Kan. July 20, 2000) 8 United States v. Chen, 820 F. Supp. 1205 (N.D. Cal. 1992) 27 United States v. N
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
gict02 Fireel61214/Rag Pt* 4I 2515 TABLE OF AUTHORITIES Page(s) Cases United States v. Boustani, 932 F.3d 79 (2d Cir. 2019) 3 United States v. Bradshaw, No. 00-40033-04-DES, 2000 WL 1371517 (D. Kan. July 20, 2000) 8 United States v. Chen, 820 F. Supp. 1205 (N.D. Cal. 1992) 27 United States v. C
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
CONCLUSION 38 ii EFTA00154514 TABLE OF AUTHORITIES Page(s) Cases United States v. Boustani, 932 F.3d 79 (2d Cir. 2019) 3 United States v. Bradshaw, No. 0040033-04-DES, 2000 WL 1371517 (D. Kan. July 20, 2000) 8 United States v. Chen, 820 F. Supp. 1205 (N.D. Cal. 1992) 27 United States v. N
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
CONCLUSION 38 ii EFTA00094291 TABLE OF AUTHORITIES Page(s) Cases United States v. Boustani, 932 F.3d 79 (2d Cir. 2019) 3 United States v. Bradshaw, No. 0040033-04-DES, 2000 WL 1371517 (D. Kan. July 20, 2000) 8 United States v. Chen, 820 F. Supp. 1205 (N.D. Cal. 1992) 27 United States v. N
Entities connected to both Second Circuit and Joshuah Taylor Bradshaw

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