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Case 1:20-cr-00330-AJN Document4 Filed 07/02/20 Page 2 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK AR RE RR Em Xx UNITED STATES OF AMERICA -V.- i 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. nce Ee RR RTE RR EERE ETRE x THE GOVERNMENT’S MEMORANDUM IN SUPPORT OF DETENTION For the reasons set forth herein, the Government respectfully submits that Ghislaine Maxwell, the defendant, poses an extreme risk of flight; that she will not be able to rebut the statutory presumption that no condition or combination of conditions will reasonably assure the appearance of the defendant as required, 18 U.S.C. § 3142(e)(3)(E); and that the Court should therefore order her detained. The charges in this case are unquestionably serious: the Indictment alleges that Ghislaine Maxwell, in partnership with Jeffrey Epstein, a serial sexual predator, exploited and abused young girls for years. Asa result of her disturbing and callous conduct, Maxwell now faces the very real prospect of serving many years in prison. The strength of the Government’s evidence and the substantial prison term the defendant would face upon conviction all create a strong incentive for the defendant to flee. That risk is only amplified by the defendant’s extensive international ties, her citizenship in two foreign countries, her wealth, and her lack of meaningful ties to the United States. In short, Maxwell has three passports, large sums of money, extensive international connections, and absolutely no reason to stay in the United States and face the possibility of a lengthy prison sentence. DOJ-OGR-00001488