DOJ-OGR-00000914.jpg

Case 21-770, Document 20-1, 04/01/2021, 3068530, Page4 of 31 These conditions would support a complaint for cruel and unusual punishment for a convicted felon. Ms. Maxwell is not one. She is innocent unless and until she is proven guilty beyond a reasonable doubt — an event which is highly unlikely given the lack of evidence against her. Despite the district court’s exhortations regarding the strength of the evidence against Ms. Maxwell, the truth is that the government’s so-called “evidence,” though voluminous, is palpably weak. It consists of anonymous, untested hearsay accusations about events that are alleged to have occurred decades ago, accusations which only surfaced when the government faced public outrage over the inexplicable death of Jeffrey Epstein, while in their custody. The “Epstein Effect” clouded the judgment of the prosecutors into charging Ms. Maxwell because it needed a scapegoat, the Bureau of Prisons into putting Ms. Maxwell on suicide watch because Epstein died on their watch, the media into an absolute frenzy, and many other fair- minded people into viewing Ms. Maxwell as guilty even though no evidence has been presented against her. DOJ-OGR-00000914