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JN Document 18 Filed 07/10/20 Page 3 of 26 TABLE OF AUTHORITIES Page(s) Cases Hung v. United States, 439 U.S. 1326 (1978) 16 United States v. Ahdellatif El Mokadem, No. I9-CR-646 (AJN), 2020 WL 3440515 (S.D.N.Y. June 23, 2020) 17 United States v. Alindato-Perez, 627 F. Supp. 2d 58 (D.P.R. 2009) 18 United
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
JN Document 18 Filed 07/10/20 Page 3 of 26 TABLE OF AUTHORITIES Page(s) Cases Hung v. United States, 439 U.S. 1326 (1978) 16 United States v. Ahdellatif El Mokadem, No. I9-CR-646 (AJN), 2020 WL 3440515 (S.D.N.Y. June 23, 2020) 17 United States v. Alindato-Perez, 627 F. Supp. 2d 58 (D.P.R. 2009) 18 United
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
JN Document 18 Filed 07/10/20 Page 3 of 26 TABLE OF AUTHORITIES Page(s) Cases Hung v. United States, 439 U.S. 1326 (1978) 16 United States v. Ahdellatif El Mokadem, No. I9-CR-646 (AJN), 2020 WL 3440515 (S.D.N.Y. June 23, 2020) 17 United States v. Alindato-Perez, 627 F. Supp. 2d 58 (D.P.R. 2009) 18 United
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
JN Document 18 Filed 07/10/20 Page 3 of 26 TABLE OF AUTHORITIES Page(s) Cases Hung v. United States, 439 U.S. 1326 (1978) 16 United States v. Ahdellatif El Mokadem, No. I9-CR-646 (AJN), 2020 WL 3440515 (S.D.N.Y. June 23, 2020) 17 United States v. Alindato-Perez, 627 F. Supp. 2d 58 (D.P.R. 2009) 18 United
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
JN Document 18 Filed 07/10/20 Page 3 of 26 TABLE OF AUTHORITIES Page(s) Cases Hung v. United States, 439 U.S. 1326 (1978) 16 United States v. Ahdellatif El Mokadem, No. I9-CR-646 (AJN), 2020 WL 3440515 (S.D.N.Y. June 23, 2020) 17 United States v. Alindato-Perez, 627 F. Supp. 2d 58 (D.P.R. 2009) 18 United
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
JN Document 18 Filed 07/10/20 Page 3 of 26 TABLE OF AUTHORITIES Page(s) Cases Hung v. United States, 439 U.S. 1326 (1978) 16 United States v. Ahdellatif El Mokadem, No. I9-CR-646 (AJN), 2020 WL 3440515 (S.D.N.Y. June 23, 2020) 17 United States v. Alindato-Perez, 627 F. Supp. 2d 58 (D.P.R. 2009) 18 United
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 Ahdellatif El Mokadem and New York Region

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Stephen Hawking
PERSON
United States
LOCATION
Dominguez
PERSON
Metropolitan Correctional Center
ORGANIZATIONSecond Circuit
ORGANIZATIONFederal Bureau of Prisons
ORGANIZATIONthe Metropolitan Detention Center
ORGANIZATIONMark S. Cohen
PERSONKarni
PERSONBoustani
PERSONPretrial Services
ORGANIZATIONSalerno
PERSONMoscaritolo
PERSONBodmer
PERSONCrowell
PERSON
Kashoggi
PERSONAudrey Cher
PERSONSean Hecker
PERSON