3
Shared Docs
3
Same-Page
4 / 3
Mentions
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
orandum Opinion and Order Respectfully submitted, MARKUS/MOSS PLLC 40 N.W. Third Street Penthouse One markuslaw.com By: /s/ David Oscar Markus DAVID OSCAR MARKUS Florida Bar Number 119318 [email protected] CERTIFICATE OF SERVICE I CERTIFY that a true and correct copy of the foregoing was e-filed
humiliating memories of my life. I will hold onto these memories forever, but these memories are my motivation to stay out of trouble, your Honor." United States v. Tiffany Days, April 29, 2021, which can be accessed at: https://tinyurl.com/ytf8cyw5. The judge in that case was upset, finding: "it is the find
SAFFIAN MARKUS/MOSS PLLC By: Is/ /s/ Leah S. Saffian LEAH S. SAFFIAN California Bar Number 11 I. " markuslaw.com By: Is/ David Oscar Markus DAVID OSCAR MARKUS Florida Bar Number [email protected] EFTA00089463 CERTIFICATE OF COMPLIANCE I CERTIFY that this petition complies with the type-volu
s in the United States, her strong desire to return to her family in the United States, and her intention to establish her innocence at her trial in the United States. 2 EFTA00096551 CageSegite$410)3Oacaltdit fitietIV/0021F lot 6111:16707/21gefaitief 301 3 LAW OFFICES OF BOBBI C. STERNHEIM In the face of the
California Bar Number 121796 11 MARKUS/MOSS PLLC *Counsel of Record 40 N.W. Third Street, PH 1 Miami, Florida 33128 By: Is/ David Oscar Markus DAVID OSCAR MARKUS Florida Bar Number 19318 EFTA00096531 Case 21-58, Document 89-1, 05/17/2021, 3102450. Page14 of 14 CERTIFICATE OF COMPLIANCE I CERTIFY t
Entities connected to both United States and DAVID OSCAR

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSONthe Southern District
LOCATION
Prince Andrew
PERSON
the United States District Court
ORGANIZATIONFederal Bureau of Prisons
ORGANIZATION
United States Department of Justice
ORGANIZATION
Larry Page
PERSON
Tiffany Trump
PERSON
ALISON J. NATHAN
ORGANIZATIONColleen McMahon
PERSON
Alison J. Nathan
PERSON
Foley Square
LOCATIONR. App
PERSONAppellant
ORGANIZATION
Orwell
PERSON
Thurgood Marshall
PERSONCourthouse
ORGANIZATIONDavid Oscar Markus
PERSON