DOJ-OGR-00001124.jpg

Cased 20-C/Qd3GO4AUNNt Dib2uiPe/tl G70 2Fti| SO A2ABM/ 26a GeAgs 26 2PA5 2. Ms. Maxwell’s Counsel Was in Regular Contact with the Government Prior to Her Arrest At no time, however, did Ms. Maxwell intend to flee or hide from the government, as the government argued at the last bail hearing. In fact, her intent was exactly the opposite. As her spouse’s letter makes clear, after spending a few months away a Ms. Maxwell noved i so that she could be within driving distance of the prosecutors in New York in case they wished to speak to her. (Ex. A § 12) (“|Ghislaine| was adamant to not only stay in the United States to fight the smears against her, but to be within driving distance of New York.”). Contrary to the impression given by the government, Ms. Maxwell was not “changing locations on multiple occasions” as if she were a fugitive from justice. (Tr. 87). After Ms. Maxwell moved into the house in New Hampshire in December 2019, she remained there continuously for approximately seven months until her airest. (See Ex. B) (“|S|he was finally able to locate a place where she could not be moving around constantly and collect herself to fight for her life and to clear her name.”). Ms. Maxwell, through her counsel, was also in regular contact with the government from the moment of Epstein’s arrest up the time of her own arrest, as would be customary in such situations. Defense counsel corresponded by email, spoke on the phone, or had in- person meetings with government in July, August, September, and October 2019, and also in January and March 2020. The timeline attached to this submission illustrates the extent of these contacts. (Ex. R). Defense counsel also requested an opportunity to be heard in the event that the government was considering any charging decisions against Ms. Maxwell. We were never given that opportunity, which is uncharacteristic for the Southern District of New York, nor were we given any notice of her impending arrest. 22 DOJ-OGR-00001124