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Case 21-58, Document 76, 04/19/2021, 3080288, Paged of 30 contrary. Not a single on of the anonymous accusers saw or heard what purportedly happened to the other accusers. Not a single one of the anonymous accusers will be able to corroborate the 25-year old stories of the other accusers. Indeed, their stories are contradictory, not corroborating. At a real hearing, the defense will demonstrate that each of the witness’ stories has dramatically changed over the years. At first, none of the anonymous accusers even mentioned Ms. Maxwell. As they hired the same law firm, sought money and fame, joined a movement, and only after Epstein died, did the accusers start to point the finger at Ms. Maxwell. Far from corroboration, this is fabrication. The district judge erred in relying on the Indictment as proof that the Government’s case 1s strong. 4. Because there was no meaningful proffer, the Government’s reliance on United States v. LaFontaine, 210 F.3d 125, 131 (2d Cir. 2000) and United States v. Martir, 782 F.2d 1141, 1145 (2d Cir. 1986), is misplaced. Resp.§/34. In fact, those cases highlight the court’s error. In LaFontaine, for example, the bail revocation hearing lasted three days where the government’s proffer included providing tape recordings, transcripts, and an affidavit for the court. No such evidentiary proffer DOJ-OGR-00020295