Epstein Secrets

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,

eover, this should not be a bar to granting bail. The proposed conditions ensure her presence at home in plain sight of monitored, and under strict Pretrial supervision. D. Ms. Maxwell Has Waived Her Extradition Rights and Could Not Seek Refuge in the United Kingdom or France At the initial hearing, t

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,

eover, this should not be a bar to granting bail. The proposed conditions ensure her presence at home in plain sight of monitored, and under strict Pretrial supervision. D. Ms. Maxwell Has Waived Her Extradition Rights and Could Not Seek Refuge in the United Kingdom or France At the initial hearing, t

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,

g bail. The proposed conditions ensure her presence at home in plain sight of her sister (and the security guards), GPS- monitored, and under strict Pretrial supervision. D. Ms. Maxwell Has Waived Her Extradition Rights and Could Not Seek Refuge in the United Kingdom or France At the initial hearing, t

United States v. Bohn, 330 F. Supp. 2d 960 (W.D. Tenn. 2004) 15 United States v. Bolero, 604 F. Supp. 1028 (S.D. Fla. 1985) 15 United States v. Boustani, 356 F. Supp. 3d 246 (E.D.N.Y.), aff'd, No. 19-344, 2019 WL 2070656 (2d Cir. Mar. 7, 2019) 28 United States v. Boustani, 932 F.3d 79 (2d Or. 2019)

to granting bail. The proposed conditions ensure her presence at home in plain sight of (and the security guards), GPS- monitored, and under strict Pretrial supervision. D. Ms. Maxwell Has Waived Her Extradition Rights and Could Not Seek Refuge in the United Kingdom or France At the initial hearing, t

he evidence of a lack of candor is, if anything, stronger now than in July 2020, as it is clear to the Court that the Defendant's representations to Pretrial Services were woefully incomplete. That lack of candor raises significant concerns as to whether the Court has now been provided a full and accurat

in which defendants of lesser means are detained pending trial while wealthy defendants are released to self-funded private jails." United States v. Boustani, 932 F.3d 79, 82 (2d Cir. 2019). As in Boustani, the Defendant in the present case would be detained regardless of her wealth, and "if a similarly

627 F. Supp. 2d 58 (D.P.R. 2009) 18 United States v. Bodmer, No. 03-cr-947(SAS), 2004 WL 169790 (S.D.N.Y. Jan. 28. 2004) 16 United States v. Boustani, 932 F.3d 79 (2d Cir. 2019) 20 United States y Carrillo-Villa, 20-MJ-3073 (SLC) 8 United States v. Chandler, 19-CR-867 (PAC), 2020 WL 1528120

continue to need security guards to protect her upon release. Under the circumstances, if the Court requires it, the security guards could report to Pretrial Services.16 10 In United States v. Houston!, 932 F.3d 79 (2d Cir. 2019), the Second Circuit curtailed the circumstances under which a court can gra