DOJ-OGR-00001078.jpg

be N Ww ws Oo OY ~] oO Ke) Ww a OY 20 21 22 23 24 25 Case 21-770, Document 20-2, 04/01/2021, 3068530, Page137 of 200 k7e2MaxC kjc detention was appropriate in that case on risk of And, again, that conduct had passed, and Jeffrey was — Epstein was not point, your Honor, to suggest that agreement, and it I want to respond with respect - at that 74 Flight alone. point significant time a Foreign citizen. LO the NPA. At this the defense has articulated no legal basis the defendant is shielded by the nonprosecution simply doesn't make sense that the decision in this case is somehow tactical to avoid concerns about the NPA, that nonprosecution agreement and stated b connection with bail proceedings in that matter that this office whatsoever with respec any kind of individual. office whatsoever. Your Honor, evaluate the question of fell within the scope of when the government charged Je the government's strong view that in short, rey the time period within the Epstein with conduct for th in court it is t to any kind of imoor bail this is that agreement does not bind conduct or That agreement does not bind this tant for the court to given the to circumstances. view each of The defense's argument the government's argumen you review the totality of xtensive international fF the her unknown ties, the court about her resources proposal which provides absolu al i circumstances in essence, the tality of attempts to ts as absolute. But when the defendant's her conduct over the past year, to flee, finances and unwillingness to be more candid with her specific bail tely no security to the court -- SOUTHERN D STRIC TRE (212) 805-0300 PORTERS, P a Gs DOJ-OGR-00001078