DOJ-OGR-00005693.jpg

Case 1:20-cr-00330-PAE Document 388 Filed 10/29/21 Page6of14 e Ms. Maxwell moved residences and switched her primary phone number (which she registered under the name ““G Max”) and email address. ! e At the time of her arrest, Ms. Maxwell allegedly ignored the direction of FBI agents to open the front door of her residence and instead moved into an interior room of the house.” e During a security sweep of the house, FBI agents found a cell phone wrapped in tin foil on top of a desk.? Ms. Maxwell thoroughly rebutted each of these points in her second bail motion. See 12/14/2020 Def.’s Mem. in Supp. of Renewed Mot. for Bail (Dkt. 97) at 18-25. Ms. Maxwell offered not just argument in response, but independent factual corroboration of her position that stands in direct opposition to the government’s incorrect and improper inferences. For example, Ms. Maxwell provided a letter from her spouse, who confirmed that Ms. Maxwell’s decision to leave her family, move residences, and eventually settle in New Hampshire—where she remained continuously for over seven months until her arrest—was a difficult choice that was motivated by the pressing need to protect herself and her family from media intrusion and potential violent threats, not by a desire to evade law enforcement. See id., Ex. A JJ 8-12; see also id., Ex. B at 2-4. Letters provided by other friends and family members attested to the relentless media harassment they themselves received and the severe consequences they endured simply for being associated with Ms. Maxwell. See, e.g., id., Exs. B at 3 & Dat 2. Ms. Maxwell also provided an affidavit from the head of the security company providing security to Ms. Maxwell, who explained the circumstances surrounding her actions on the ! 7/2/2020 Gov’t Mem. in Supp. of Detention (Dkt. 004) at 8; 12/18/2020 Gov’t Mem. in Opp. to Def’s Renewed Mot. for Release (Dkt. 100) at 20. 2 7/13/2020 Gov’t Reply Mem. in Supp. of Detention (Dkt. 022) at 7; 7/14/2020 Tr. of Bail Hrg. at 33:22-25; 12/18/2020 Gov’t Mem. in Opp. to Def’s Renewed Mot. for Release (Dkt. 100) at 21-22. 37/13/2020 Gov’t Reply Mem. in Supp. of Detention (Dkt. 022) at 7; 7/14/2020 Tr. of Bail Hrg. at 34:1-5; 12/18/2020 Gov’t Mem. in Opp. to Def’s Renewed Mot. for Release (Dkt. 100) at 22. DOJ-OGR-00005693