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be N Ww ws Oo OY ~] oO Ke) a fan) = be N Ww = Hs Oo a OY a ~] a oO a Ke) 20 21 22 23 24 25 Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 56 of 91 56 k7e2MaxC kjc hiding. She is a risk of flight because she changed her e-mail and phone number. That's what we heard in the opening brief. Well, what happened? Something the government, frankly, should know about, because it was certainly public, last year, ina civil litigation, in August of 2019, right around the time of the arrest of Mr. Epstein, the Second Circuit ruled that certain records in one of the civil cases should be unsealed and released to the public. That was done. There was no stay at the moment. The demand was issued, and the documents were released. Certain of those documents were supposed to be redacted and sometimes they were and sometimes they were not, documents including e-mail addresses, Social Security numbers, names, phone numbers, the sorts of things your Honor, I am sure, has to deal with all the time in these kinds of Situations. But as it turned out, for whatever reason, some of the documents were not redacted and her e-mail address was revealed. Shortly after that, she starts getting strange e-mails. Her phone is hacked, and she had to change e-mails and change the account. Now she has got a phone that has legal materials on it, correspondence with her counsel in civil litigation that's been hacked, so she keeps it. Why does she keep it? Because she is in civil litigation. Her obligation is to keep evidence, not destroy it, and is advised that a way to keep it SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00001933