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e Evidence 9 C. The Characteristics of the Defendant 12 D. Conditions of Confinement 29 CONCLUSION 33 EFTA00103381 TABLE OF AUTHORITIES Jackson v. Goon!, 664 F. Supp. 2d 307 (S.D.N.Y. 2009) 27 United States v. Abdullahu, 488 F. Supp. 2d 433 (D.N.J. 2007) 19 United States v. Banki, 10 Cr.
efendant has the kind of ties to this country that come with any employment in the United States or any dependents living here. Indeed, as noted in the Pretrial Services Report, the defendant stated in July that she has no children and has no current employment. (Pretrial Services Report at 3). The Renewed Bail Motion fail
by a preponderance of the evidence that "that no conditions could reasonably assure the defendant's presence at trial." See. e.a., Vnited States v. Jackson 823 F.2d 4, 5 (2d Cir. 1987); 18 U.S.C. § 3142. "[T]he constitutional limits on a detention period based on dangerousness to the community may be l
under section 3142(g) is within the 'special province' of the district court." paulino 335 F. Supp. at 610. At the outset, it should be noted that the Pretrial Services Report, dated July 12, 2019, concludes that: "The defendant poses a risk of nonappearance for the following reasons: 1. [Mr. Epstein's] Extensive foreign
by a preponderance of the evidence that "that no conditions could reasonably assure the defendant's presence at trial." See. e.a., Vnited States v. Jackson 823 F.2d 4, 5 (2d Cir. 1987); 18 U.S.C. § 3142. "[T]he constitutional limits on a detention period based on dangerousness to the community may be l
under section 3142(g) is within the 'special province' of the district court." paulino 335 F. Supp. at 610. At the outset, it should be noted that the Pretrial Services Report, dated July 12, 2019, concludes that: "The defendant poses a risk of nonappearance for the following reasons: 1. [Mr. Epstein's] Extensive foreign
by a preponderance of the evidence that "that no conditions could reasonably assure the defendant's presence at trial." See. e.a., Vnited States v. Jackson 823 F.2d 4, 5 (2d Cir. 1987); 18 U.S.C. § 3142. "[T]he constitutional limits on a detention period based on dangerousness to the community may be l
under section 3142(g) is within the 'special province' of the district court." paulino 335 F. Supp. at 610. At the outset, it should be noted that the Pretrial Services Report, dated July 12, 2019, concludes that: "The defendant poses a risk of nonappearance for the following reasons: 1. [Mr. Epstein's] Extensive foreign
by a preponderance of the evidence that "that no conditions could reasonably assure the defendant's presence at trial." See. e.a., Vnited States v. Jackson 823 F.2d 4, 5 (2d Cir. 1987); 18 U.S.C. § 3142. "[T]he constitutional limits on a detention period based on dangerousness to the community may be l
under section 3142(g) is within the 'special province' of the district court." paulino 335 F. Supp. at 610. At the outset, it should be noted that the Pretrial Services Report, dated July 12, 2019, concludes that: "The defendant poses a risk of nonappearance for the following reasons: 1. [Mr. Epstein's] Extensive foreign
nsideration when denying bail. "A motion for reconsideration may not be used ... as a vehicle for relitigating issues already decided by the Court." Jackson v. Goord, 664 F. Supp. 2d 307, 313 (S.D.N.Y. 2009) (internal quotation marks omitted). The Court already considered and rejected the defendant's ef
efendant has the kind of ties to this country that come with any employment in the United States or any dependents living here. Indeed, as noted in the Pretrial Services Report, the defendant stated in July that she has no children and has no current employment. (Pretrial Services Report at 3). The Renewed Bail Motion fail
nfinement 29 CONCLUSION 33 EFTA00093263 Cfiese.20-MOCO:304,Agnit 1:WDeu 6443111 JBE2 1 F I i t 8.255B3Reg EFISSeat 35 56 TABLE OF AUTHORITIES Jackson v. Goon!, 664 F. Supp. 2d 307 (S.D.N.Y. 2009) 27 United States v. Abdullahu, 488 F. Supp. 2d 433 (D.N.J. 2007) 19 United States v. Bank!, 10 Cr.
efendant has the kind of ties to this country that come with any employment in the United States or any dependents living here. Indeed, as noted in the Pretrial Services Report, the defendant stated in July that she has no children and has no current employment. (Pretrial Services Report at 3). The Renewed Bail Motion fail
Entities connected to both Michael Jackson and the Pretrial Services Report

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Julie K. Brown
PERSON
John F. Kennedy
PERSON
Department of Justice
ORGANIZATION
George Mitchell
PERSON
New York
LOCATION
Michael Cohen
PERSON
Bradley Edwards
PERSONFBI
ORGANIZATIONThe New York Post
ORGANIZATION
James Baker
PERSONthe Southern District
LOCATION
Oliver Stone
PERSON
New York City
LOCATION
United Kingdom
LOCATION
Palm Beach
LOCATION
U.S. Virgin Islands
LOCATION
Southern District of New York
ORGANIZATION