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Case 1:20-cr-00330-AJN Document18 Filed 07/10/20 Page 17 of 26 cases related to Epstein in the Southern District of New York and has sat for depositions in those cases. Similarly, throughout the course of the criminal investigation of this case, which has been publicly reported on for nearly a year, Ms. Maxwell has remained in the United States. Indeed, on July 7, 2019, the day after Epstein’s arrest, Ms. Maxwell reached out to the prosecutors in the Southern District of New York, through counsel, and maintained regular contact with them right up to the point of her arrest. The government’s broad assertion that Ms. Maxwell has engaged in “frequent international travel” in the last three years (Gov. Mem. at 6) obscures the critical point: she has not left the country even once since Epstein’s arrest. Ms. Maxwell’s decision to remain in the United States after Epstein’s arrest and subsequent death in August 2019 is particularly significant because any incentive she may have had to flee would have been even more acute at that time. Within days of Epstein’s death, a steady stream of press articles began turning the public’s attention to Ms. Maxwell—wrongly substituting her for Epstein—and speculating that she had become the prime target of the government’s investigation.” Adding even more fuel to this fire, several of the women claiming to be victims of Epstein’s abuse began publicly calling for her immediate arrest and prosecution. Despite the increasing risk of being criminally charged, and the media firestorm that was redirected toward her after Epstein’s death, and despite having ample opportunity to leave the country, Ms. Maxwell stayed in the United States for almost an entire year until she was arrested. These actions weigh heavily in favor of release. See United States v. Friedman, ” See, e.g., Spotlight turns on Jeffrey Epstein’s British socialite ‘fixer’ Ghislaine Maxwell after his suicide — but will she be prosecuted?, Daily Mail (Aug. 10, 2019), https:/Avww.dailymail.co.uk/news/article-7344765/Spotlight-turns- Jeffrey-Epsteins-fixer-Ghislaine-Maxwell-suicide.html; Ghislaine Maxwell: the woman accused of helping Jeffrey Epstein groom girls, The Guardian (Aug. 12, 2019), https:/Avww.theguardian.com/us-news/2019/aug/12/ghislaine- max well-woman-accused-jeffrey-epstein-groom-girls; British socialite Ghislaine Maxwell in spotlight after Epstein’s apparent suicide, NBC News (Aug. 12, 2019), https:/(www.nbcnews.com/news/us-news/british-socialite- ghislaine-maxwell-spotlight-after-epstein-s-apparent-suicide-n1041111. 13 DOJ-OGR-00001597