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over 6,500 national media articles. That exceeds the number of articles that mentioned such high-profile defendants as Harvey Weinstein, Bill Cosby, Joaquin "El Chapo" Guzman Loera, and Keith Raniere in the 90-day period following their arrests, combined. The media coverage has ruthlessly vilified her a
s. Maxwell's Health and Ability to Prepare Her Defense 35 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,
s about MCC reaches the public, it typically comes in sensational stories about alleged mega- criminals such as Epstein, Sammy "The Bull" Gravano, or Joaquin "El Chapo" Guzman being held there—the crimes with which they are charged completely obscuring the jail itself. Moreover, while Americans broadly p
, Lebanese salesman Jean Boustani faces allegations that he bribed Mozambican officials to obtain business for shipbuilder Privinvest. While some of Boustani's co-defendants are charged with FCPA violations, he himself is not. He suggested in a recent motion to dismiss that such charges wouldn't have stuc
s about MCC reaches the public, it typically comes in sensational stories about alleged mega- criminals such as Epstein, Sammy "The Bull" Gravano, or Joaquin "El Chapo" Guzman being held there—the crimes with which they are charged completely obscuring the jail itself. Moreover, while Americans broadly p
, Lebanese salesman Jean Boustani faces allegations that he bribed Mozambican officials to obtain business for shipbuilder Privinvest. While some of Boustani's co-defendants are charged with FCPA violations, he himself is not. He suggested in a recent motion to dismiss that such charges wouldn't have stuc
over 6,500 national media articles. That exceeds the number of articles that mentioned such high-profile defendants as Harvey Weinstein, Bill Cosby, Joaquin "El Chapo" Guzman Loera, and Keith Raniere in the 90-day period following their arrests, combined. The media coverage has ruthlessly vilified her a
s. Maxwell's Health and Ability to Prepare Her Defense 35 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,
over 6,500 national media articles. That exceeds the number of articles that mentioned such high-profile defendants as Harvey Weinstein, Bill Cosby, Joaquin "El Chapo" Guzman Loera, and Keith Raniere in the 90-day period following their arrests, combined. The media coverage has ruthlessly vilified her a
s. Maxwell's Health and Ability to Prepare Her Defense 35 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,
over 6,500 national media articles. That exceeds the number of articles that mentioned such high-profile defendants as Harvey Weinstein, Bill Cosby, Joaquin "El Chapo" Guzman Loera, and Keith Raniere in the 90-day period following their arrests, combined. The media coverage has ruthlessly vilified her a
ge131 of 351 82 k7e2MaxC kjc 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 quoting there from United States v. Boustani, 932 F.3d 79, (2d Cir. 2019). The court concludes as follows: First, the nature and circumstances of the offense here weigh in favor of detention
Entities connected to both Joaquin and Boustani

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONthe Southern District
LOCATION
Department of Justice
ORGANIZATION
United States
LOCATION
Prince Andrew
PERSONEl Chapo
PERSON
Donald Trump
PERSON
New York
LOCATION
Michael Cohen
PERSON
United Kingdom
LOCATIONGuzman
PERSON
Julie K. Brown
PERSON
Metropolitan Correctional Center
ORGANIZATION
Michael Jackson
PERSONFederal Bureau of Prisons
ORGANIZATIONLeon Black
PERSONFBI
ORGANIZATION
George W. Bush
PERSON
Virginia Giuffre
PERSON