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Case 1:20-cr-00330-AJN Document 97-11 Filed 12/14/20 Page 3 of 3 So I am in a position to speak to Guislaine's character. | had gotten to know her vital personality quite well when she was young. And even though | wasn't in direct touch with her later on, all these Maxwell children are quite “tight” - they've always stayed closely in touch with each other. Thus whenever I'd speak to any of her elders — Philip, Anne, Isabel and Christine, I'd also hear reports not just about their own lives and activities, but also Kevin's and Ian's, as well about Ghislaine's life. Her siblings consistently reported for about a decade that she was enjoying life while starting her own charity. So what kind of a character is Ghislaine? I can testify without the least doubt that she is mature, sensitive, thoughtful, honest and, like all her siblings, strong-willed, determined and quite obviously grounded in good human values. She does not lie. She is no “chicken” - it would be totally unlike her to run away from the charges leveled against her by the Government. In fact, the idea of not “facing the music” is totally against the values of every single Maxwell, because both their parents always emphasized personal responsibility — specifically to face Bob's temper. These people consider running away their greatest shame. Furthermore, in facing their father's criticisms, they were trained, over and over, to defend themselves with real courage. So I have no doubt that not only did Ghislaine — despite the blaring headlines in the press and the governments’ own opposition to bail alleging incorrectly that she is a “flight risk” — made absolutely no attempt to leave the US at any time in 2019, but has stayed to fight the civil accusations against her starting earlier. Nor do I have any doubt whatsoever that she fully intends to defend herself to the limit of her energy based upon her actual innocence and that above all she wants to go to trial and she is categorically not a flight risk. DOJ-OGR-00002054