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Case 1:20-cr-00330-AJN Document 97 Filed 12/14/20 Page 12 of 45 was arrested and has shown no signs of abating. Indeed, in the three months after her arrest, Ms. Maxwell was the subject of over 6,500 national media articles. That exceeds the number of articles that mentioned such high-profile defendants as Harvey Weinstein, Bill Cosby, Joaquin “El Chapo” Guzman Loera, and Keith Raniere in the 90-day period following their arrests, combined. The media coverage has ruthlessly vilified her and prejudged her guilt, and has exposed her family and friends to harassment, physical threats, and other negative consequences. But Ms. Maxwell is not the person the media has portrayed her to be; far from it. And her response to these unfounded allegations remains unchanged: she resolutely and vehemently denies them, and she is steadfastly committed to remaining in this country, where she has been since Epstein’s arrest in July 2019, to fight them in court. For Ms. Maxwell to flee, she would have to abandon her spouse ee. She will not risk destroying the lives and financial well-being of those she holds most dear to live as a fugitive during a worldwide pandemic. In fact, every action Ms. Maxwell has taken from the time of Epstein’s arrest up to the time of the first bail hearing was designed to protect her spouse P| from harassment, economic harm, and physical danger. Ms. Maxwell wants to stay in New York and have her day in court so that she can clear her name and return to her family. Justice is not reserved solely for the victims of a crime; it is for the accused as well. Here, justice would be served by granting Ms. Maxwell bail under the comprehensive conditions we propose. The alternative is continued detention under oppressive conditions that are unprecedented for a non-violent pretrial detainee, which significantly impair her ability to participate in her defense and prepare for trial and which jeopardize her physical health and psychological wellbeing. DOJ-OGR-00001984