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be NO k7e2MaxC kjc regarding the det 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 Page 84 of 91 84 believes that the representations made to Pretrial Services Fendant's finances likely do not provide a complete and candid picture of the resources available. Additionally, while Ms. Maxwell does have some family and personal connections to any dependents, United States leads the court pose an insurmountable burden assessments of crime, sig risk the United States, the absence of nificant Family ties or employment in the flight would not to conclude that in Cas for her, as is often th of f1 In sum, th tentia the government connections, the pot resources all Now, maintains she the arrest of authorities and investigation in be implicated, traveled, and th t's ca create both the motive and opportunity in th is no Jeffr e comb Ll leng se at is defendant's substantial e face ta fl ey ight. the the seriousness of ination of this stage, th of th th strength of sentence, the defendant's foreign financial to flee. this the defendant of vidence, ight risk. She notes that even after Epstein and even after the implication by apparently, she did not leave the United States. out To the contrary, contac these not flee previously, t with the government. factual representations. give the press that there was an ongoing to his alleged coconspirators and that she may She hasn't side the United States in over a year through counsel, she has stayed in The government doesn't contest The fact that Ms. Maxwell did n these circumstances, is a SOUTH ERN D STR CT RE PORTERS, P.C. (212) 805-0300 DOJ-OGR-00001961