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lly certain that bail would be refused in an extradition case in circumstances where the requested person had absconded from criminal proceedings in the United States prior to trial and in breach of bail; and (c) on the basis of the information currently known, it is highly unlikely' that Ghislaine Maxwell would b
iiiiest:20-?gOODBOAMt Itibtfinfldift1100221, $0611293180p2Pigel 351 4 Article 3 of the Bilateral Extradition Treaty signed on April 23, 1996 between the United States of America and France stipulates that "The requested State is not bound to grant the extradition of any of its nationals, but the Executive Power of the United
well will not do that, and should be granted bail. G. The Alternative to Bail Is Confinement Under Oppressive Conditions that Impact Ms. Maxwell's Health and Ability to Prepare Her Defense Granting bail to Ms. Maxwell is all the more appropriate and necessary because the past few months have shown that Ms. Maxwell cannot adequately pa
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
Ms. Maxwell's Presence in Court 34 EFTA00065717 G. The Alternative to Bail Is Confinement Under Oppressive Conditions that Impact Ms. Maxwell's Health and Ability to Prepare Her Defense 35 CONCLUSION 38 ii EFTA00065718 TABLE OF AUTHORITIES Page(s) Cases United States v. Boustani, 932 F.3d 79 (2d Cir. 2019) 3 United State
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
Ms. Maxwell's Presence in Court 34 EFTA00154513 G. The Alternative to Bail Is Confinement Under Oppressive Conditions that Impact Ms. Maxwell's Health and Ability to Prepare Her Defense 35 CONCLUSION 38 ii EFTA00154514 TABLE OF AUTHORITIES Page(s) Cases United States v. Boustani, 932 F.3d 79 (2d Cir. 2019) 3 United State
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
Ms. Maxwell's Presence in Court 34 EFTA00094290 G. The Alternative to Bail Is Confinement Under Oppressive Conditions that Impact Ms. Maxwell's Health and Ability to Prepare Her Defense 35 CONCLUSION 38 ii EFTA00094291 TABLE OF AUTHORITIES Page(s) Cases United States v. Boustani, 932 F.3d 79 (2d Cir. 2019) 3 United State
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
1136tifMaiht:02 El lae6129.4/2thg Phfre c10 (51515 G. The Alternative to Bail Is Confinement Under Oppressive Conditions that Impact Ms. Maxwell's Health and Ability to Prepare Her Defense 35 CONCLUSION 38 EFTA00093218 aste12207a0OITEMOAMI lattatitegict02 Fireel61214/Rag Pt* 4I 2515 TABLE OF AUTHORITIES Page(s) Cases United St
Entities connected to both United States and Health and Ability to Prepare Her Defense

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
Michael Cohen
PERSON
Stephen Hawking
PERSON
United Kingdom
LOCATION
Vicky Ward
PERSON
Harvey Weinstein
PERSONSecond Circuit
ORGANIZATION
Denver
LOCATION
David Boies
PERSON
Brady
PERSON
Denmark
LOCATION
New Hampshire
LOCATIONJeffrey Pagliuca
PERSONCohen & Gresser LLP
ORGANIZATIONKarni
PERSONBoustani
PERSON