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ay Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 24 of 91 k7e2MaxC kjc legal N Ww ws Oo OY ~] oO Ke) Ww a OY 20 21 22 23 24 25 reasonably assure her return to court and, your Honor, det presumption. Turning First to offense and the strength this case arises from minors for unlawful travel to engage in unlawf a conspiracy to do the same. Your Honor, disturbing and the na very serious. conspiracy to sexually exploit the vulnerabl community. not going to go in victims beyond what briefing; but, and groomed girls who were as youn as of the nature and seriousness of fFendant has not come anywhere close to rebutting that th ul to conceal her crimes. abuse by Jeffrey with a preference that the defendant participated in some of herself, SOUTHERN D including sexual Epstein, to details, 1 1 gb y t's contained in the indictment a that the defendant perjured herself, your a man wh vidence, The indictment ture and circumstances of th sexual activity and enticing minors 24 presumption that there are no conditions that could the the indictment in the defendant's role in transporting CO sexual active and participating in the off further charges that she lied under oath the charged conduct in this case is ns one The defendant is charged with participating in a In order to protect the privacy of Honor, the indictment lleges, g as 14 years old about for members of fF the victims, our I'm the particular and our the defendant enticed sexual o she knew was a predator for underaged girls. The indictment alleges lized massages in which the vic these acts o £ abuse STR CT RE PORT ERS, (212) 805-0300 tims DOJ-OGR-00001901