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communal spaces, and limited access to hygiene products' [in correctional facilities] make community spread all but unavoidable." United States v. Williams-Bethea, No. 18-CR-78 (AJN), 2020 WL 2848098, at *5 (S.D.N.Y. June 2, 2020) (citation and internal quotation marks omitted). The risks are further enhanced
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
communal spaces, and limited access to hygiene products' [in correctional facilities] make community spread all but unavoidable." United States v. Williams-Bethea, No. 18-CR-78 (AJN), 2020 WL 2848098, at *5 (S.D.N.Y. June 2, 2020) (citation and internal quotation marks omitted). The risks are further enhanced
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
communal spaces, and limited access to hygiene products' [in correctional facilities] make community spread all but unavoidable." United States v. Williams-Bethea, No. 18-CR-78 (AJN), 2020 WL 2848098, at *5 (S.D.N.Y. June 2, 2020) (citation and internal quotation marks omitted). The risks are further enhanced
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
communal spaces, and limited access to hygiene products' [in correctional facilities] make community spread all but unavoidable." United States v. Williams-Bethea, No. 18-CR-78 (AJN), 2020 WL 2848098, at *5 (S.D.N.Y. June 2, 2020) (citation and internal quotation marks omitted). The risks are further enhanced
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
communal spaces, and limited access to hygiene products' [in correctional facilities] make community spread all but unavoidable." United States v. Williams-Bethea, No. 18-CR-78 (AJN), 2020 WL 2848098, at *5 (S.D.N.Y. June 2, 2020) (citation and internal quotation marks omitted). The risks are further enhanced
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
communal spaces, and limited access to hygiene products' [in correctional facilities] make community spread all but unavoidable." United States v. Williams-Bethea, No. 18-CR-78 (AJN), 2020 WL 2848098, at *5 (S.D.N.Y. June 2, 2020) (citation and internal quotation marks omitted). The risks are further enhanced
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 Williams-Bethea and New York Region

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PERSONDeutsch
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Conway
PERSONMarc Dreier
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Michael Cohen
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Bernie Madoff
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Jeffrey Epstein
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PERSONSecond Circuit
ORGANIZATIONBodmer
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Ghislaine Maxwell
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Stephen Hawking
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LOCATIONKarni
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LOCATIONMark S. Cohen
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