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Case 21-58, Document 39-1, 04/01/2021, 3068530, Page30 of 31 CONCLUSION Ms. Maxwell faces old, anonymous accusations that have never been tested. In any other case, she would have been released long ago. But because of the “Epstein effect,” she is being detained and in truly unacceptable conditions. All we are asking for is a chance to defend the case. We respectfully request that Ms. Maxwell be released on reasonable conditions of bail or that the case be remanded for an evidentiary hearing. Respectfully submitted, MARKUS/MOSS PLLC 40 N.W. Third Street Penthouse One Miami, Florida 33128 Tel: (805) 379-6667 Fax: (805) 379-6668 markuslaw.com By: /s/ David Oscar Markus DAVID OSCAR MARKUS Florida Bar Number 119318 dmarkus@markuslaw.com 28 DOJ-OGR-00019858