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be NO Case 21-770, Document 20-2, 04/01/2021, 3068530, Page147 of 200 k7e2MaxC kjc believes that the represen regarding the defendant's Ww ws Oo OY ~] oO Ke) a fan) = be N Ww = Hs Oo a OY a ~] a oO a Ke) 20 21 22 23 24 25 complete and candid picture of Additional and personal connections to any dependents, sig United States leads the court pose an insurmountable burden risk assessments of ly, while Ms. Maxwell tations made to 84 Services Pretrial finances likely do not provide a the resources available. does have some family nificant the United States, the absence of in the Family for her, at Flight. In sum, th crime, the potentia the government's ca connections, and th resources all Now, in th maintains she is no the arrest of Jeffr e combination of Ll length of se at is defendant's substantial e face of ta ey ties or employment to conclude that as is often th the seriousness of would not flight in Cas the th sentence, th strength of this stage, th create both the motive and opportunity this vidence, def ndant's foreign financial to flee. the defendant She flight risk. notes that even after Epstein and even af authorities and Frer the implication by the press that there was an ongoing investigation into his alleged coconspirators and that she may be implicated, traveled, apparentl To the contrary, contact with the government. these not flee previously Yr factual representations. , given these circumstances, she did not leave the United States. The fact through counsel, She hasn't outside the United States in over a year she has stayed in The government doesn't contest that Ms. Maxwell did is a SOUTH ERN DISTRICT RE (212) 805-0300 PORTERS, P.C. DOJ-OGR-00001088