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2 13 14 15 16 17 18 19 20 21 22 23 24 25 ties. While she is a naturalized citizen of the United States, she is a citizen of France and the United Kingdom. She grew up in the United Kingdom and has a history of extensive international travel. She owns a property in the United Kingdom. Your Honor, the
s hiding and we have evidence, your Honor, that the defendant was making plans to leave the country. That is the situation, frankly, in the U.S. v. Zarger case, the case by Judge Gleeson in 2000, that the government cites in its brief, but of course doesn't discuss the facts. There is nothing to that
r financial condition and assets, and those of her spouse, for the last five years; (3) irrevocable waivers of her right to contest extradition from the United Kingdom and France and expert opinions stating that it would be highly unlikely that Ms. Maxwell would be able to resist extradition in the implausible even
s hiding and we have evidence, your Honor, that the defendant was making plans to leave the country. That is the situation, frankly, in the U.S. v. Zarger case, the case by Judge Gleeson in 2000, that the government cites in its brief, but of course doesn't discuss the facts. There is nothing to that
she would be able to resist extradition on that basis, see Tr. at 83:1843:20, the Defendant now offers to waive her right to extradition from both the United Kingdom and France, along with expert opinions reports claiming that such waivers would likely make it possible to resist an extradition request from the U
Page: EFTA00013317 →observed, "home detention with electronic monitoring does not prevent flight; at best, it limits a fleeing defendant's head start." United States v. Zarger, No. 00- CR-773-S-1 (JG), 2000 WL 1134364, at *I (E.D.N.Y. Aug. 4, 2000). Furthermore, while the Defendant now represents that she would be released
Page: EFTA00013325 →dant's extensive international ties would make it exceptionally easy for her to flee and live abroad. The defendant was born in France and raised in the United Kingdom, where she attended school. Although she became a naturalized citizen of the United States in 2002, she also remains a citizen of the United Kingdo
Page: EFTA00018511 →ing device. At best, home confinement with electronic monitoring would merely reduce her head start should she decide to flee. See United States v. Zarger, No. 00 Cr. 773, 2000 WL 1134364, at *1 8 EFTA00018513 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 4 Filed 07/02/20 Page 10 of 10 (E.D.N
Page: EFTA00018514 →Entities connected to both United Kingdom and Zarger

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSON
Julie K. Brown
PERSON
Department of Justice
ORGANIZATION
Michael Jackson
PERSON
Stephen Hawking
PERSONthe Southern District
LOCATION
Michael Cohen
PERSON
George Mitchell
PERSONMartin Weinberg
PERSONFBI
ORGANIZATIONJane Doe
PERSONEmmy Taylor
PERSON
U.S. Virgin Islands
LOCATION
Palm Beach
LOCATION
Anderson
PERSONJeffrey Pagliuca
PERSON
Alexander Acosta
PERSON