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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
Attorneys for Defendant BY: MARK S. COHEN CHRISTIAN R. EVERDELL HADDON MORGAN & FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA LAURA A. MENNINGER SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00093124 Case 21-770, Document 17-2, 04/01/2021, 3068296. Page51 of 351 k7e2MaxC kjc THE
efendant is a dual citizen of the United States. As well, we have been informed that there is an extradition treaty between the United Kingdom and the United States. The extradition process would be lengthy, the outcome would be uncertain, and it's very likely that the defendant would not be detained during the
Attorneys for Defendant BY: MARK S. COHEN CHRISTIAN R. EVERDELL HADDON MORGAN & FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA LAURA A. MENNINGER SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00066216 k7e2MaxC kjc THE COURT: Good afternoon, everyone. This is Judge Nathan presiding
d there are a number of factors that are considered, the first being, and I think it is important to recognize, Mr. Epstein was granted immunity by the United States Attorney in the District of Florida for the conduct that I believe he is going to be questioned about. And I don't believe that it is appropriate f
Attorneys for Plaintiff BY: SIGRID S. McCAWLEY MEREDITH L. SCHULTZ HADDON MORGAN AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY PAGLIUCA LAURA A. MENNINGER DAVIS WRIGHT TREMAINE LLP Attorneys for Respondent Sharon Churcher BY: ERIC J. FEDER LAW OFFICES OF Attorneys BY: GREGORY L. RACHEL S. GREGOR
n abuse of discretion occurs if the district court fails to make the required factual findings, or if those factual findings are clearly erroneous." United States v. Juvenile Male No. 1, 47 F.3d 68,71 (2d Cir. 1995) (citation omitted). B. The district court erred in ordering the unsealing. There are "two rela
, SCHILLER & FLEXNER, LLP 16 Attorney for Plaintiff BY: SIGRID S. MCCAWLEY 17 HADDON, MORGAN, AND FOREMAN, P.C. 18 Attorney for Defendant BY: LAURA A. MENNINGER 19 20 21 22 23 24 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00075527 Case 20-2413, Document40,08/20/2020. 2913550. Page52 o
on is at issue. Tax compliance does not go to a reputation, it is a private matter. Second, there is no evidence in this case that any government, ither United States or Australia, believes that SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011331 10 id. 12 13 14 L5 16 ne) 18 life) 2
THE UNIVERSITY OF UTAH For Plaintiff BY: PAUL G. CASSELL, ESQ. HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRICT R (212) 805- PORT 0300 ERS, HOUSE_OVERSIGHT_011304 10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24 25
Entities connected to both United States and LAURA A. MENNINGER

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSONthe Southern District
LOCATION
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Alexander Acosta
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSON
Bill Clinton
PERSON
Julie K. Brown
PERSON
Virginia Giuffre
PERSONMaria Farmer
PERSONSouthern District
LOCATION
Joe Biden
PERSONMartin Weinberg
PERSON
Southern District of New York
ORGANIZATION
Michael Cohen
PERSON
Paul Cassell
PERSON