DOJ-OGR-00001379.jpg

Case 21-770, Document 57, 04/19/2021, 3080288, Page? of 30 erroneously adopted its conclusory proffer. 5. Ms. Maxwell’s intention to evade the media does not even marginally amount to risk of flight. Resp.{33. The Government does not dispute that the media placed a bounty on Ms. Maxwell or that she was being stalked by them before her arrest. Of course she took measures to protect herself and her family, just as government lawyers and judges do when their safety is at issue. Ms. Maxwell was at her home in the United States. The Government admits that it knew where she was. It had such confidence that it could arrest her whenever it chose that it orchestrated her arrest to coincide with a press conference replete with incendiary demonstrative aids. And it is worth repeating that the Government does not claim that Ms. Maxwell — a 59-year old woman with no prior criminal history — is a danger to the community. She is no monster, but she is being treated like one because of the “Epstein effect.” 6. The Government’s contention that Ms. Maxwell receives more time than other inmates at MDC to “review her discovery” and “communicate with her attorneys” does not prove anything about whether she is actually able to effectively prepare her defense. Ms. Maxwell needs more time with her lawyers and discovery than almost any other MDC DOJ-OGR-00001379