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Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 31 of 91
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THE
COURT:
fore moving on
There is a basic dispute within the papers as to, I
think, efforts similar
to hide
efforts
risk of
indication of
I'm sorry,
from authorities,
Flight or whether,
Ms.
Moe, if
from those points.
notoriety and public interest that
following the
reasons.
indictment o
fF Mr.
effort to protect privacy and hide
Epstein,
to the ones you have described that
which would certainly be
[ may pause you
are
an
in light of
the
the case has generated
whether it was an
from press
for privacy
determination be resolved, if
what is your general response
assertion?
MS. MOE:
Yes,
As we discussed in our reply brief
view,
the court's determination with respect to bail
How does the government suggest that
you agree tha
to the veraci
your Honor.
that
factual
should, and
CY
ld
eo)
your Honor,
£ that
in our
there is no question these circumstances ar
relevant to
for a number of
Fendant's motive,
Fendant has the
that she is
reasons.
The first is, irrespective of the def
these facts make clear to the court that the det
ability to live in hiding, that she is good at it,
willing to do it even if it compromises her relationship and
contacts wi
the real estat
th other people and,
agent underscores,
as the in
formation provided by
SOUTHERN D
STR
CT
PORT
RE ERS,
(212)
805-0300
she is good at it and that
31
DOJ-OGR-00001908