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ctly address the concern the Court expressed at the last bail hearing that Ms. Maxwell did not have "any dependents [or] significant family ties" to the United States. (Tr. 84). If Ms. Maxwell were to flee, she would be leaving behind the family that has been the center of her life , she would be abandoning her s
Her Arrest 18 1. Ms. Maxwell Was Trying to Protect Herself from a Media Frenzy and from Physical Threats 18 2. Ms. Maxwell's Counsel Was in Regular Contact with the Government Prior to Her Arrest 22 3. Ms. Maxwell Did Not Try to Avoid Arrest, Nor Was She "Good At" Hiding 23 D. Ms. Maxwell Has Wai
ctly address the concern the Court expressed at the last bail hearing that Ms. Maxwell did not have "any dependents [or] significant family ties" to the United States. (Tr. 84). If Ms. Maxwell were to flee, she would be leaving behind the family that has been the center of her life , she would be abandoning her s
Her Arrest 18 1. Ms. Maxwell Was Trying to Protect Herself from a Media Frenzy and from Physical Threats 18 2. Ms. Maxwell's Counsel Was in Regular Contact with the Government Prior to Her Arrest 22 3. Ms. Maxwell Did Not Try to Avoid Arrest, Nor Was She "Good At" Hiding 23 D. Ms. Maxwell Has Wai
ctly address the concern the Court expressed at the last bail hearing that Ms. Maxwell did not have "any dependents [or] significant family ties" to the United States. (Tr. 84). If Ms. Maxwell were to flee, she would be leaving behind the family that has been the center of her life for five years, she would be aba
8 1. Ms. Maxwell Was Trying to Protect Herself and Her Family from a Media Frenzy and from Physical Threats 18 2. Ms. Maxwell's Counsel Was in Regular Contact with the Government Prior to Her Arrest 22 3. Ms. Maxwell Did Not Try to Avoid Arrest, Nor Was She "Good At" Hiding 23 D. Ms. Maxwell Has Wai
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
ent Before Her Arrest 18 1. Ms. Maxwell Was Trying to Protect Herself a Media Frenzy and from Physical Threats 2. Ms. Maxwell's Counsel Was in Regular Contact with the Government Prior to Her Arrest from 3. Ms. Maxwell Did Not Try to Avoid Arrest, Nor Was She "Good At" Hiding D. Ms. Maxwell Has Waive
Entities connected to both United States and Regular Contact

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSONthe Southern District
LOCATION
Michael Cohen
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Stephen Hawking
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Vicky Ward
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Harvey Weinstein
PERSONSecond Circuit
ORGANIZATION
Denmark
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New Hampshire
LOCATIONJeffrey Pagliuca
PERSONCohen & Gresser LLP
ORGANIZATIONKarni
PERSONBoustani
PERSONMark S. Cohen
PERSONR. Everdell
PERSONRaniere
PERSONMORGAN & FOREMAN
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Bill Cosby
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