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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
before the July trial, adding two counts involving a fourth anonymous accuser. 7 EFTA00093052 Case 21-770. Document 17-1, 04/01/2021, 3068296, Pagel 0 of 31 indictment (which is, of course, true in every criminal case) and to the nature of the charges in the abstract. The district court bought int
ng In re von Bulow, 828 F.2d 94, 99 (2d Cir. 1987))). At that point, particularly in the Internet age, the horse is irrevocably out of the barn. See United States v. Bolton, F. Supp. 3d , 2020 WL 3401940, at *4 (D.D.C. No. 1:20- CV-1580 (RCL), June 20, 2020) (declining to enjoin publication of a book by form
a scheme causing her to be "sexually abused and trafficked" by Jeffrey Epstein. 2 EFTA00074911 Case 20-2413, Document 10-1, 07/30/2020, 2896538, Pagel 0 of 38 Plaintiff, a public figure required to prove actual malice, litigated her defamation action by trying to transform it into a criminal or tort
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
n. App. p 116, ¶ffil 8-10; p 119 9¶ 27; p 122, ¶ 12; p 123, 51114, 16; p 124,9120. 3 EFTA00075485 Case 20-2413, Document 40, 08/20/2020, 2913550, Pagel 0 of 74 Plaintiff chose this course of action because even she had to admit that numerous of her statements were false. Discovery in the case was co
Entities connected to both United States and Pagel 0

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
Julie K. Brown
PERSON
Southern District of New York
ORGANIZATION
Stephen Hawking
PERSON
Colorado
LOCATIONSecond Circuit
ORGANIZATION
Denver
LOCATION
David Boies
PERSON
Cynthia Nixon
PERSON
Robert Mueller
PERSON
The New York Times
ORGANIZATIONJeffrey Pagliuca
PERSONSigrid McCawley
PERSON
Larry Page
PERSON
Richard Nixon
PERSON
Foley Square
LOCATIONSweet
PERSON