DOJ-OGR-00001902.jpg

be N Ww ws Oo OY ~] oO Ke) Ww a OY 20 21 22 23 24 25 Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 k7e2MaxC kjc wer fully nude. sometimes partially or these minors to engage in additional acts of Epstein. The indictment makes plain, your a single incident or a single victim or anything isolated but Honor, abuse with Je Page 25 of 91 25 She also encouraged rey this was not ~ instead, it was an ongoing scheme to abuse multiple victims for a pattern of years. This is except the Given the strength of the serious charges in the indictment, strong incentive for the defendant her to become at that and The history and characteristics of tionally serious conduct. government's evidence and there is an incredibly an incentive for to flee, fugitive to avoid being held accountable to avoid a lengthy prison sentence. the defendant tha underscores the risk of flight t she poses. The Pretrial Services report confirms that the defendant has been moving from place to place for some time, recently it appears that she spent your Honor; and most the last year making concerted ef around New England, most recently to New Forts to conceal her whereabouts whilst moving which Hampshire, that particular -- will discuss momentarily with respect to THE COURT: Ms. Moe? MS. MOE: -——- property. THE COURT: Ms. Moe, there is one assertion in the defense papers that I don't think I have seen the government's response to, and that is through counsel, kept in the contention that Ms. Maxwell, touch with the government since the SOUTHERN D STRICT RE PORTERS, P.C. (212) 805-0300 DOJ-OGR-00001902