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amplified by the defendant's extensive international ties, her citizenship in two foreign countries, her wealth, and her lack of meaningful ties to the United States. In short, Maxwell has three passports, large sums of money, extensive international connections, and absolutely no reason to stay in the United Sta
f production—not a burden of persuasion—to rebut that presumption by coming forward with evidence that [she] does not pose . . . a risk of flight." See United States v. English, 629 F.3d 311, 319 (2d Cir. 2011) (quotation omitted). This rebuttable presumption can be readily satisfied, United States v. Conway, No
ugh she became a naturalized citizen of the United States in 2002, she also remains a citizen of the United Kingdom and France. Travel records from United States Customs and Border Protection ("CBP") reflect that she has engaged in frequent international travel, including at least fifteen international flights in the last three years to l
amplified by the defendant's extensive international ties, her citizenship in two foreign countries, her wealth, and her lack of meaningful ties to the United States. In short, Maxwell has three passports, large sums of money, extensive international connections, and absolutely no reason to stay in the United Sta
ugh she became a naturalized citizen of the United States in 2002, she also remains a citizen of the United Kingdom and France. Travel records from United States Customs and Border Protection ("CBP") reflect that she has engaged in frequent international travel, including at least fifteen international flights in the last three years to l
amplified by the defendant's extensive international ties, her citizenship in two foreign countries, her wealth, and her lack of meaningful ties to the United States. In short, Maxwell has three passports, large sums of money, extensive international connections, and absolutely no reason to stay in the United Sta
ugh she became a naturalized citizen of the United States in 2002, she also remains a citizen of the United Kingdom and France. Travel records from United States Customs and Border Protection ("CBP") reflect that she has engaged in frequent international travel, including at least fifteen international flights in the last three years to l
May 13. 2013 11 Svect No, NYC1305000206 Q. On your prior trips to the United States lit you engage in any kind of employment while residing in the United Staten? A. I helped my friend out at a restaurant linnet:as. Q. What is the Name of your friend and what is rte name of the restaurant? A. Tho restaurant
United States dollars (Seen, verified end returned by CRPO Yououfr CBPO Juan G. Hernandez) witnonned by Q. Do you have any medical conditions that United States Customs and Border Protection should ba made aware of? A. I have a cold. Q. Are you currently taking any prescription medication? A. I do not take any prescription medication.
ion Page for Fore) I-867A Daw May 13. 2013 Q. On your prior trips to the United States lit you engage in any kind of employment while residing in the United Staten? A. I helped my friend out at a restaurant somercinms. Q. What is the Name of your and what is tlia name restaurant? A. The restaurant is named
United States dollars (Seen, verified and returned by CBPO Yououf; CBPO Juan C. Hernandez) witnessed by Q. Do you have any medical conditions that United States Customs and Border Protection should be made aware of? A. I have a cold. Q. Aro you currently taking any prescription medication? A. I do not take any prescription medication.
amplified by the defendant's extensive international ties, her citizenship in two foreign countries, her wealth, and her lack of meaningful ties to the United States. In short, Maxwell has three passports, large sums of money, extensive international connections, and absolutely no reason to stay in the United Sta
ugh she became a naturalized citizen of the United States in 2002, she also remains a citizen of the United Kingdom and France. Travel records from United States Customs and Border Protection ("CBP") reflect that she has engaged in frequent international travel, including at least fifteen international flights in the last three years to l
amplified by the defendant's extensive international ties, her citizenship in two foreign countries, her wealth, and her lack of meaningful ties to the United States. In short, Maxwell has three passports, large sums of money, extensive international connections, and absolutely no reason to stay in the United Sta
ugh she became a naturalized citizen of the United States in 2002, she also remains a citizen of the United Kingdom and France. Travel records from United States Customs and Border Protection ("CBP") reflect that she has engaged in frequent international travel, including at least fifteen international flights in the last three years to l
amplified by the defendant's extensive international ties, her citizenship in two foreign countries, her wealth, and her lack of meaningful ties to the United States. In short, Maxwell has three passports, large sums of money, extensive international connections, and absolutely no reason to stay in the United Sta
ugh she became a naturalized citizen of the United States in 2002, she also remains a citizen of the United Kingdom and France. Travel records from United States Customs and Border Protection ("CBP") reflect that she has engaged in frequent international travel, including at least fifteen international flights in the last three years to l
Entities connected to both United States and United States Customs and Border Protection

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONthe Southern District
LOCATION
John F. Kennedy
PERSON
Southern District of New York
ORGANIZATION
Michael Jackson
PERSON
United Kingdom
LOCATION
Anderson
PERSON
Audrey Strauss
PERSONPerez
PERSONBradford
LOCATIONLaFontaine
PERSONGleeson
PERSONCasteneda
PERSON
New England
LOCATION
Ferranti
PERSONMoscaritolo
PERSONPatriarca
PERSONAlindato
PERSON