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Case 1:20-cr-00330-AJN Document 97 Filed 12/14/20 Page 16 of 45 II. Ms. Maxwell Should Be Granted Bail Under the Proposed Strict Bail Conditions A. Ms. Maxwell Has Deep Family Ties to the United States and Numerous Sureties to Support Her Bond Attached to this submission are letters from Ms. Maxwell’s spouse and from numerous close family members and friends, many of whom have agreed to serve as sureties to support Ms. Maxwell’s renewed bail application. (See Exs. A-N, W-X). Far from the cruel caricature that the press has so recklessly depicted since the arrest of Jeffrey Epstein, these letters demonstrate that Ms. Maxwell is generous, loving, and devoted to her family and friends, and that her life is firmly rooted in this country with her spouse fF ee. The signatories of these letters have known Ms. Maxwell for decades, and some for her entire life. All know her to be the antithesis of what the government has alleged. They trust her completely, including with their minor children. These people have stepped forward to support Ms. Maxwell, despite the considerable risk that, if their names ever become public, they will be subjected to some of the same relentless and harassing media intrusion and personal threats that Ms. Maxwell has experienced for years. As a sign of their confidence that Ms. Maxwell will remain in this country, the sureties have agreed to sign their own bonds and to post meaningful pledges of cash or property in amounts that would cause them significant financial distress if Ms. Maxwell were to violate her bail conditions. These letters directly address the concern the Court expressed at the last bail hearing that Ms. Maxwell did not have “any dependents [or] significant family ties” to the United States. (Tr. 84). If Ms. Maxwell were to flee, she would be leaving behind the family that has been the center of her life ae. she would be abandoning her spouse | 10 DOJ-OGR-00001988