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le income from inheritances. (Def. Ex. O at 5). This is significant, given that the Government has produced to the defendant in discovery a copy of Jeffrey Epstein's will, which includes a $10 million cash grant to the defendant. The financial report further shows that the defendant apparently spent the last five
1994 and 1997. The defendant played a critical role in the scheme by helping to identify, entice, and groom minor girls to engage in sex acts with Epstein. The defendant's presence as an adult woman normalized Epstein's abusive behavior, and she even took part in at least some acts of sexual abuse. Tog
ng the sexual abuse of multiple minor victims by Jeffrey Epstein between approximately 1994 and 1997. The
al. See, e.g., United States v. Namer, 238 F.3d 425, 2000 WL 1872012, at •2 (6th Cir. Dec. 12, 2000); Chins, 2013 WL 3802012 at *2; United States v. Abdullahu, 488 F. Supp. 2d 433, 443 (D.N.J. 2007) ("The inability to extradite defendant should he flee weighs in favor of detention."). Beyond being imposs
10) 15 United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009) 27 United States v. English, 629 F.3d 311 (2d Cir. 2011) 7 United States v. Epstein, 155 F. Supp. 2d 323 (E.D. Pa. 2001) 28 United States v. Epstein, 425 F. Supp. 3d 306 (S.D.N.Y. 2019) 15, 29 United States v. Esposito, 309 F. Su
le income from inheritances. (Def. Ex. O at 5). This is significant, given that the Government has produced to the defendant in discovery a copy of Jeffrey Epstein's will, which includes a $10 million cash grant to the defendant. The financial report further shows that the defendant apparently spent the last five
ng the sexual abuse of multiple minor victims by Jeffrey Epstein between approximately 1994 and 1997. The
of Confinement 29 CONCLUSION 33 EFTA00103381 TABLE OF AUTHORITIES Jackson v. Goon!, 664 F. Supp. 2d 307 (S.D.N.Y. 2009) 27 United States v. Abdullahu, 488 F. Supp. 2d 433 (D.N.J. 2007) 19 United States v. Banki, 10 Cr. 008 (JFK), Dkt. 7 (S.D.N.Y. Jan. 21, 2010), aff'd, 369 F. App'x 152 (2d Cir. 2
ne 29, 2020. a grand jury in the Southern District of New York returned a six-count Indictment against the Defendant, charging her with facilitating Jeffrey Epstein's sexual abuse of multiple minor victims between approximately 1994 and 1997. See Dkt. No. 1. On July 2, 2020, the Indictment was unsealed, and that
t 30 years, might flee to the United Kingdom or France if granted bail, despite the fact that she did not leave the country for nearly a year after Epstein's arrest. (Dkt. 22 at 6.) The government asserted in its reply brief that France "does not extradite its citizens to the United States pursuant to F
eve of the one-year anniversary of the arrest of Jeffrey Epstein, creating the misimpression that Ms. Maxw
u 6443111 JBE2 1 F I i t 8.255B3Reg EFISSeat 35 56 TABLE OF AUTHORITIES Jackson v. Goon!, 664 F. Supp. 2d 307 (S.D.N.Y. 2009) 27 United States v. Abdullahu, 488 F. Supp. 2d 433 (D.N.J. 2007) 19 United States v. Bank!, 10 Cr. 008 (JFK), Dkt. 7 (S.D.N.Y. Jan. 21, 2010), aff'd, 369 F. App'x 152 (2d Cir. 2
Entities connected to both Jeffrey Epstein and Abdullahu

Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
John F. Kennedy
PERSON
United States
LOCATION
Glenn Dubin
PERSONSouthern District
LOCATION
Michael Cohen
PERSON
Department of Justice
ORGANIZATION
Samantha Power
PERSONFBI
ORGANIZATION
Michael Jackson
PERSON
Southern District of New York
ORGANIZATION
Audrey Strauss
PERSON
United Kingdom
LOCATIONSecond Circuit
ORGANIZATIONPeterson
PERSONMorrison
PERSON
Stanton
PERSON
Bernie Madoff
PERSON
Rahm Emanuel
PERSON