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Case 1:20-cr-00330-AJN Document 100 Filed 12/18/20 Page 8 of 36 would not pose an insurmountable burden for her.” (Tr. 84). The Court recognized the defense arguments that the defendant did not leave the United States after Epstein’s arrest and was in contact with the Government through counsel, but emphasized that the defendant may have expected that she would not be prosecuted. (Tr. 84-85). The Court also noted that the defendant “did not provide the government with her whereabouts,” and that the “[c]ircumstances of her arrest ... may cast some doubt on the claim that she was not hiding from the government, a claim that she makes throughout the papers and here today, but even if true, the reality that Ms. Maxwell may face such serious charges herself may not have set in until she was actually indicted.” (Tr. 85). Based on all of those factors, the Court found that the Government had carried its burden of demonstrating that the defendant “poses a substantial actual risk of flight.” (Tr. 86). The Court then concluded that “even the most restrictive conditions of release would be insufficient” to ensure the defendant’s appearance. (/d.). Acknowledging that the defense’s initial bail package represented only a fraction of the defendant’s assets, the Court found that “even a substantially larger package would be insufficient.” (/d.). Although the defendant “apparently failed to submit a full accounting or even close to full accounting of her financial situation,” the Court implicitly rejected the defense’s offer to provide additional information by determining that “/e/ven if the picture of her financial resources were not opaque, as it is, detention would still be appropriate.” (Tr. 86-87 (emphasis added)). That conclusion was informed not only by the defendant’s “significant financial resources,” but also her “demonstrated sophistication in hiding those resources and herself.” (Tr. 87). “Even assuming that Ms. Maxwell only wanted to hide from the press and the public,” the Court emphasized that the defendant’s “recent conduct underscores her extraordinary capacity to evade detection, even in the face of what the defense has acknowledged to be extreme and unusual efforts to locate her.” (/d.). Given that sophistication, DOJ-OGR-00002169