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be N Ww ws Oo OY ~] oO Ke) Ww a OY 20 21 22 23 24 25 Case 21-58, Document 39-2, 04/01/2021, 3068530, Page88 of 200 25 k7e2MaxC kjc wer fully nude. sometimes partially or these minors to engage in additional acts of Epstein. The indictment makes plain, your a Single incident or a single victim or anything isolated but Honor, abuse with Je She also encouraged rey this was not ~ instead, it was an ongoing scheme to abuse multiple victims for a pattern of years. This is exceptionally serious conduct. Given th the serious charges in the indictment, strong incentive strength of for the defendant to the government's evidence and there is an incredibly an incentive for flee, her to become at and The history and characteristics of underscores the risk of that fugitive to avoid being held accountable to avoid a lengthy prison sentence. the defendant The Pretrial Flight that she poses. Firms Services report cont from place to place recently it appears concerted ef around New that England, most recently to New for some time, that the defendant has been moving your Honor; and most she spent the last year making Forts to conceal her whereabouts whilst moving which Hampshire, that particular -- will discuss momentarily with respect to THE COURT: Ms. Moe? MS. MOE: -—-——- property. THE COURT: Ms. Moe, there is one assertion in the defense papers that I don't think I have seen the government's response to, and that is the contention that Ms. Maxwell, through counsel, kept in touch with the government since the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00019947