he evidence of a lack of candor is, if anything, stronger now than in July 2020, as it is clear to the Court that the Defendant's representations to Pretrial Services were woefully incomplete. That lack of candor raises significant concerns as to whether the Court has now been provided a full and accurat

e defendant has been indicted, there will be no preliminary hearing, and that takes us to the question of bail. In that regard, I have received the Pretrial Services report. I have also received a letter from the SOUTHERN DISTRICT REPORTERS. P.C. EFTA00015609 --- PAGE BREAK --- j782epsC kjc 4 5 6

e defendant has been indicted, there will be no preliminary hearing, and that takes us to the question of bail. In that regard, I have received the Pretrial Services report. I have also received a letter from the SOUTHERN DISTRICT REPORTERS, P.C. EFTA00015664 --- PAGE BREAK --- j782epsC kjc 4 5 6

address the merits, the government attempts to dismiss the significance of Ms. Maxwell's relationship with her spouse, noting that Ms. Maxwell told Pretrial Services that she was in the process of getting a divorce and that her spouse did not step forward as a co-signer at the initial bail hearing. (Id.

continue to need security guards to protect her upon release. Under the circumstances, if the Court requires it, the security guards could report to Pretrial Services.16 10 In United States v. Houston!, 932 F.3d 79 (2d Cir. 2019), the Second Circuit curtailed the circumstances under which a court can gra

address the merits, the government attempts to dismiss the significance of Ms. Maxwell's relationship with her spouse, noting that Ms. Maxwell told Pretrial Services that she was in the process of getting a divorce and that her spouse did not step forward as a co-signer at the initial bail hearing. (Id.

s this letter to inform the Court that the parties have entered into deferred prosecution agreements (the "Agreements"), which have been approved by Pretrial Services and are included for the Court's consideration.' After a thorough investigation, and based on the facts of this case and the personal circ

receive additional minutes for good cause; e. Establish procedures when a staff assisted call may be made for good cause, including procedures for Pretrial and Holdover inmates. The institution will involve the Regional Correctional Programs Administrator in developing the Institution Supplement. 7.

eover, this should not be a bar to granting bail. The proposed conditions ensure her presence at home in plain sight of monitored, and under strict Pretrial supervision. D. Ms. Maxwell Has Waived Her Extradition Rights and Could Not Seek Refuge in the United Kingdom or France At the initial hearing, t

12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. WEINGARTEN: The last thing we did today was refuse to answer questions. What we said at Pretrial is heaven forbid we make a mistake, and in terms of assets, we wanted to be precise. So there was no refusal. There was a request for time to supp

12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. WEINGARTEN: The last thing we did today was refuse to answer questions. What we said at Pretrial is heaven forbid we make a mistake, and in terms of assets, we wanted to be precise. So there was no refusal. There was a request for time to supp

12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. WEINGARTEN: The last thing we did today was refuse to answer questions. What we said at Pretrial is heaven forbid we make a mistake, and in terms of assets, we wanted to be precise. So there was no refusal. There was a request for time to supp

g bail. The proposed conditions ensure her presence at home in plain sight of her sister (and the security guards), GPS- monitored, and under strict Pretrial supervision. D. Ms. Maxwell Has Waived Her Extradition Rights and Could Not Seek Refuge in the United Kingdom or France At the initial hearing, t

erefore, he will be pending a UDC hearing. Should he return to SHU, he will be housed with inmate . Inmate MI is a 54-year-old White Male. He is a Pretrial inmate on a Supervised Release Violation for Failure to Register as Sex Offender. He is refusing to go to general population. % The other inmates i

eover, this should not be a bar to granting bail. The proposed conditions ensure her presence at home in plain sight of monitored, and under strict Pretrial supervision. D. Ms. Maxwell Has Waived Her Extradition Rights and Could Not Seek Refuge in the United Kingdom or France At the initial hearing, t

there has ever been a clear 29 opportunity to once again stress the 22 demonstration of no prejudice, this record 24 tremendous efficacy of The Pretrial 24 establishes that. 25 Stipulation. He puts mach of the words, 25 Judge Hay's words, •Depending upon the 62 64 1 •The Pretrial stipulation

to SHU, he will be housed with inmate + • - - - • • + . + • • • Page 33 Page 11 fb)(B>:(b)(l)(c) lis a 54-year-old White Male. He is a Pretrial inmate on a Supervised Release Violation for Failure to Register as Sex Offender. He is refusing to go to general population. h h d f bl 11 h

re, he will be pending a UDC hearing. Should he return to SHU, he will be housed with inmate Icb)(6);(b)(7>cc> ps a 54-year-old White Male. He is a Pretrial inmate on a Supervised Release Violation for Failure to Register as Sex Offender. He is refusing to go to general population. The other inmates in

g a UDC hearing. Should he return to SHU, he will be housed with inmate Page 211 Page 55 [b)(G);(b)(7)tc> lis a 54-year-old White Male. He is a Pretrial inmate on a Supervised Release Violation for Failure to Register as Sex Offender. He is refusing to go to general population. The other inmates in

. (bK7}<A> Therefore, he will be pending a UDC hearing. Should he return to SHU, he will be housed with inmate is a 54-year-old White Male. He is a Pretrial inmate on ~------------------~ a Supervised Release Violation for Failure to Register as Sex Offender. He is refusing to go to general population.