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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,
hould grant Ms. Maxwell bail on the restrictive conditions proposed below to ensure her constitutional right to prepare her defense. EFTA00065722 The Proposed Bail Conditions Ms. Maxwell now proposes the following $28.5 million bail package, which is exceptional in its scope and puts at risk everything that Ms. Maxwell h
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,
hould grant Ms. Maxwell bail on the restrictive conditions proposed below to ensure her constitutional right to prepare her defense. EFTA00094295 The Proposed Bail Conditions Ms. Maxwell now proposes the following $28.5 million bail package, which is exceptional in its scope and puts at risk everything that Ms. Maxwell h
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
ow to ensure her constitutional right to prepare her defense. EFTA00093222 Glate122076006330401 1 Da ifitAtiht in 2 'Pi laelalitatag PIO ef 61515 The Proposed Bail Conditions Ms. Maxwell now proposes the following $28.5 million bail package, which is exceptional in its scope and puts at risk everything that Ms. Maxwell h
Entities connected to both Boustani and The Proposed Bail Conditions

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSONthe Southern District
LOCATION
Michael Cohen
PERSONSecond Circuit
ORGANIZATIONKarni
PERSON
Stephen Hawking
PERSONPetrov
PERSONKhashoggi
PERSONJeffrey Pagliuca
PERSONSalvagno
PERSONMark S. Cohen
PERSON
New Hampshire
LOCATIONCohen & Gresser LLP
ORGANIZATIONRaniere
PERSONR. Everdell
PERSON
Vicky Ward
PERSON
George W. Bush
PERSONEl Chapo
PERSON