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Cased 20-C/Qd3GO4AUNNt Tibet G70 2Ftil SO A2ARM/ 26a dedg@ 24 20A5 foreign bank accounts. Ms. Maxwell is not trying to hide anything from the government. She has been entirely transparent with her finances and has filed accurate and timely joint tax returns with her spouse for the last four years, and she has put it all at risk of forfeiture if she flees under the proposed bail package. The Macalvins report and the report of ly mm give the Court a clear picture of Ms. Maxwell’s finances. Accordingly, the Court should have no pause about granting her on bail on the proposed terms. C. Ms. Maxwell Was Not Hiding from the Government Before Her Arrest 1. Ms. Maxwell Was Trying to Protect Herself from a Media Frenzy and from Physical Threats The letter from Ms. Maxwell’s spouse also forcefully debunks the fiction that Ms. Maxwell was trying to conceal her whereabouts from the government before her arrest, as the government argued at the first bail hearing. (Tr. 25). Ms. Maxwell made efforts to remove herself from the public eye solely to prevent the intrusion of the frenzied press into her personal family life and to protect herself, her spouse, hi from third parties who threatened violence. To suggest that she was a fugitive is patently wrong. After Epstein’s arrest and subsequent death in BOP custody, the media coverage of Ms. Maxwell spiked dramatically, as the press rushed to substitute Ms. Maxwell for Epstein as the target of the scandal. The graph below illustrates the volume of press articles relating to Ms. Maxwell over the course of the last five years.’ The graph shows that Ms. Maxwell was mentioned in news articles only sporadically between October 2015 and June 2019. It was not until Mr. Epstein’s arrest in July 2019 that Ms. Maxwell was thrown into the media spotlight. For example, Ms. Maxwell was mentioned in only 59 articles in total from October 2015 to June 2019. Immediately following Epstein’s arrest, however, she was ‘In order to quantify the number of articles published about Ms. Maxwell, we used Nexis NewsDesk, a media monitoring and analytics service provided by LexisNexis. 18 DOJ-OGR-00001120