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Cased 2O-LIDCBGOuATNIt Pb AuMelAtl 220 2ilGO OFFRO/2Bagedgect 200.9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK I x UNITED STATES OF AMERICA ~V.- : 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. EI! x THE GOVERNMENT’S REPLY MEMORANDUM IN FURTHER SUPPORT OF DETENTION The Government respectfully submits this reply memorandum in further support of its motion for detention, dated July 2, 2020 (the “Detention Memorandum ’’) (Dkt. 4), and in response to the defendant’s memorandum in opposition (the “Opposition Memorandum’) (Dkt. 18). The charges against Ghislaine Maxwell arise from her essential role in sexual exploitation that caused deep and lasting harm to vulnerable victims. At the heart of this case are brave women who are victims of serious crimes that demand justice. The defendant’s motion wholly fails to appreciate the driving force behind this case: the defendant’s victims were sexually abused as minors as a direct result of Ghislaine Maxwell’s actions, and they have carried the trauma from these events for their entire adult lives. They deserve to see her brought to justice at a trial. There will be no trial for the victims if the defendant is afforded the opportunity to flee the jurisdiction, and there is every reason to think that is exactly what she will do if she is released. For the reasons detailed in the Detention Memorandum, and as further discussed below, the defendant poses a clear risk of flight, and no conditions of bail could reasonably assure her continued appearance in this case. Among other concerns: (1) she is a citizen of a country that does not extradite its own citizens; (2) she appears to have access to considerable wealth DOJ-OGR-00000986