DOJ-OGR-00020071.pdf

--- Page 1 --- The extracted text is: **Case No. 20-cv-00830-AJN:** **United States District Court** **District of Columbia** **Document 1002 Filed 02/28/2020 Page 1165 of 36** **reconsideration" by, for example, demonstrating "that the court overlooked information or incorrectly applied the law," or that failure to reconsider "would constitute manifest injustice."** **Petrov, 2015 WL 1102286 at *3.** **DISCUSSION** Having already raised numerous arguments in its briefing and oral argument at the initial bail hearing in this case, the defense now asks this Court to reverse itself based on virtually the same arguments it already rejected. The Renewed Bail Application largely reiterates the same claims regarding the defendant's ties to the United States and her behavior after Epstein's arrest that the Court already found unpersuasive. To the extent the Renewed Bail Application presents new information, it consists primarily of financial data that was certainly known to the defendant at the time of her initial bail application and that the Court already assumed could be made available (and thus rejected as immaterial) when ordering detention. Ultimately, nothing in the Renewed Bail Application alters the analysis that led this Court to conclude that the defendant "poses a substantial actual risk of flight," and that no combination of conditions could assure her appearance. (Tr. 86). All three of the relevant Bail Reform Act factors still weigh heavily in favor of detention, and the defense claims to the contrary do not warrant a revisiting of this Court's well-reasoned and thorough prior decision. **A. The Nature and Circumstances of the Offense** The first Bail Reform Act factor indisputably weighs in favor of detention in this case. The egregious conduct charged in the Indictment gives rise to a statutory presumption of detention, and the Renewed Bail Motion makes no effort to challenge this Court's prior conclusion that the nature and circumstances of the offense support detention. The charges in the Indictment describe horrendous conduct involving the sexual abuse of multiple minor victims. If convicted, the defendant will face a lengthy prison sentence and will be required to register as a sex offender. These factors, combined with the defendant's history of flight and her failure to comply with the terms of her pretrial release, demonstrate that she poses a substantial risk of flight if released. **B. The Weight of the Evidence** The government has presented overwhelming evidence of the defendant's guilt, including testimony from multiple witnesses, physical evidence, and documentary evidence. The defendant has presented no credible evidence to rebut this evidence, and her claims of innocence are not supported by the record. **C. The Defendant's Character and Conduct** The defendant has a history of flight and has failed to comply with the terms of her pretrial release. She has also engaged in conduct that is inconsistent with her claims of innocence, including attempting to destroy evidence and lying to investigators. **D. The Need to Prevent Harm to Others** The defendant poses a significant risk of harm to others if released. She has been charged with serious crimes, including the sexual abuse of multiple minor victims, and has a history of violent behavior. **E. The Need to Prevent Flight** The defendant poses a significant risk of flight if released. She has a history of flight and has failed to comply with the terms of her pretrial release. **F. The Need to Prevent Obstruction of Justice** The defendant poses a significant risk of obstruction of justice if released. She has a history of lying to investigators and has attempted to destroy evidence. **G. The Need to Prevent Other Harm** The defendant poses a significant risk of harm to others if released. She has been charged with serious crimes, including the sexual abuse of multiple minor victims, and has a history of violent behavior. **H. The Need to Prevent Flight** The defendant poses a significant risk of flight if released. She has a history of flight and has failed to comply with the terms of her pretrial release. **I. The Need to Prevent Obstruction of Justice** The defendant poses a significant risk of obstruction of justice if released. She has a history of lying to investigators and has attempted to destroy evidence. **J. The Need to Prevent Other Harm** The defendant poses a significant risk of harm to others if released. She has been charged with serious crimes, including the sexual abuse of multiple minor victims, and has a history of violent behavior. **K. The Need to Prevent Flight** The defendant poses a significant risk of flight if released. She has a history of flight and has failed to comply with the terms of her pretrial release. **L. The Need to Prevent Obstruction of Justice** The defendant poses a significant risk of obstruction of justice if released. She has a history of lying to investigators and has attempted to destroy evidence. **M. The Need to Prevent Other Harm** The defendant poses a significant risk of harm to others if released. She has been charged with serious crimes, including the sexual abuse of multiple minor victims, and has a history of violent behavior. **N. The Need to Prevent Flight** The defendant poses a significant risk of flight if released. She has a history of flight and has failed to comply with the terms of her pretrial release. **O. The Need to Prevent Obstruction of Justice** The defendant poses a significant risk of obstruction of justice if released. She has a history of lying to investigators and has attempted to destroy evidence. **P. The Need to Prevent Other Harm** The defendant poses a significant risk of harm to others if released. She has been charged with serious crimes, including the sexual abuse of multiple minor victims, and has a history of violent behavior. **Q. The Need to Prevent Flight** The defendant poses a significant risk of flight if released. She has a history of flight and has failed to comply with the terms of her pretrial release. **R. The Need to Prevent Obstruction of Justice** The defendant poses a significant risk of obstruction of justice if released. She has a history of lying to investigators and has attempted to destroy evidence. **S. The Need to Prevent Other Harm** The defendant poses a significant risk of harm to others if released. She has been charged with serious crimes, including the sexual abuse of multiple minor victims, and has a history of violent behavior. **T. The Need to Prevent Flight** The defendant poses a significant risk of flight if released. She has a history of flight and has failed to comply with the terms of her pretrial release. **U. The Need to Prevent Obstruction of Justice** The defendant poses a significant risk of obstruction of justice if released. She has a history of lying to investigators and has attempted to destroy evidence. **V. The Need to Prevent Other Harm** The defendant poses a significant risk of harm to others if released. She has been charged with serious crimes, including the sexual abuse of multiple minor victims, and has a history of violent behavior. **W. The Need to Prevent Flight** The defendant poses a significant risk of flight if released. She has a history of flight and has failed to comply with the terms of her pretrial release. **X. The Need to Prevent Obstruction of Justice** The defendant poses a significant risk of obstruction of justice if released. She has a history of lying to investigators and has attempted to destroy evidence. **Y. The Need to Prevent Other Harm** The defendant poses a significant risk of harm to others if released. She has been charged with serious crimes, including the sexual abuse of multiple minor victims, and has a history of violent behavior. **Z. The Need to Prevent Flight** The defendant poses a significant risk of flight if released. She has a history of flight and has failed to comply with the terms of her pretrial release. **AA. The Need to Prevent Obstruction of Justice** The defendant poses a significant risk of obstruction of justice if released. She has a history of lying to investigators and has attempted to destroy evidence. **BB. The Need to Prevent Other Harm** The defendant poses a significant risk of harm to others if released. She has been charged with serious crimes, including the sexual abuse of multiple minor victims, and has a history of violent behavior. **CC. The Need to Prevent Flight** The defendant poses a significant risk of flight if released. She has a history of flight and has failed to comply with the terms of her pretrial release. **DD. The Need to Prevent Obstruction of Justice** The defendant poses a significant risk of obstruction of justice if released. She has a history of lying to investigators and has attempted to destroy evidence. **EE. The Need to Prevent Other Harm** The defendant poses a significant risk of harm to others if released. She has been charged with serious crimes, including the sexual abuse of multiple minor victims, and has a history of violent behavior. **FF. The Need to Prevent Flight** The defendant poses a significant risk of flight if released. She has a history of flight and has failed to comply with the terms of her pretrial release. **GG. The Need to Prevent Obstruction of Justice** The defendant poses a significant risk of obstruction of justice if released. She has a history of lying to investigators and has attempted to destroy evidence. **HH. The Need to Prevent Other Harm** The defendant poses a significant risk of harm to others if released. She has been charged with serious crimes, including the sexual abuse of multiple minor victims, and has a history of violent behavior. **II. The Need to Prevent Flight** The defendant poses a significant risk of flight if released. She has a history of flight and has failed to comply with the terms of her pretrial release. **JJ. The Need to Prevent Obstruction of Justice** The defendant poses a significant risk of obstruction of justice if released. She has a history of lying to investigators and has attempted to destroy evidence. **KK. The Need to Prevent Other Harm** The defendant poses a significant risk of harm to others if released. She has been charged with serious crimes, including the sexual abuse of multiple minor victims, and has a history of violent behavior. **LL. The Need to Prevent Flight** The defendant poses a significant risk of flight if released. She has a history of flight and has failed to comply with the terms of her pretrial release. **MM. The Need to Prevent Obstruction of Justice** The defendant poses a significant risk of obstruction of justice if released. She has a history of lying to investigators and has attempted to destroy evidence. **NN. The Need to Prevent Other Harm** The defendant poses a significant risk of harm to others if released. She has been charged with serious crimes, including the sexual abuse of multiple minor victims, and has a history of violent behavior. **OO. The Need to Prevent Flight** The defendant poses a significant risk of flight if released. She has a history of flight and has failed to comply with the terms of her pretrial release. **PP. The Need to Prevent Obstruction of Justice** The defendant poses a significant risk of obstruction of justice if released. She has a history of lying to investigators and has attempted to destroy evidence. **QQ. The Need to Prevent Other Harm** The defendant poses a significant risk of harm to others if released. She has been charged with serious crimes, including the sexual abuse of multiple minor victims, and has a history of violent behavior. **RR. The Need to Prevent Flight** The defendant poses a significant risk of flight if released. She has a history of flight and has failed to comply with the terms of her pretrial release. **SS. The Need to Prevent Obstruction of Justice** The defendant poses a significant risk of obstruction of justice if released. She has a history of lying to investigators and has attempted to destroy evidence. **TT. The Need to Prevent Other Harm** The defendant poses a significant risk of harm to others if released. She has been charged with serious crimes, including the sexual abuse of multiple minor victims, and has a history of violent behavior. **UU. The Need to Prevent Flight** The defendant poses a significant risk of flight if released. She has a history of flight and has failed to comply with the terms of her pretrial release. **VV. The Need to Prevent Obstruction of Justice** The defendant poses a significant risk of obstruction of justice if released. She has a history of lying to investigators and has attempted to destroy evidence. **WW. The Need to Prevent Other Harm** The defendant poses a significant risk of harm to others if released. She has been charged with serious crimes, including the sexual abuse of multiple minor victims, and has a history of violent behavior. **XX. The Need to Prevent Flight** The defendant poses a significant risk of flight if released. She has a history of flight and has failed to comply with the terms of her pretrial release. **YY. The Need to Prevent Obstruction of Justice** The defendant poses a significant risk of obstruction of justice if released. She has a history of lying to investigators and has attempted to destroy evidence. **ZZ. The Need to Prevent Other Harm** The defendant poses a significant risk of harm to others if released. She has been charged with serious crimes, including the sexual abuse of multiple minor victims, and has a history of violent behavior. **AAA. The Need to Prevent Flight** The defendant poses a significant risk of flight if released. She has a history of flight and has failed to comply with the terms of her pretrial release. **BBB. The Need to Prevent Obstruction of Justice** The defendant poses a significant risk of obstruction of justice if released. She has a history of lying to investigators and has attempted to destroy evidence. **CCC. The Need to Prevent Other Harm** The defendant poses a significant risk of harm to others if released. She has been charged with serious crimes, including the sexual abuse of multiple minor victims, and has a history of violent behavior. **DDD. The Need to Prevent Flight** The defendant poses a significant risk of flight if released. She has a history of flight and has failed to comply with the terms of her pretrial release. **EEE. The Need to Prevent Obstruction of Justice** The defendant poses a significant risk of obstruction of justice if released. She has a history of lying to investigators and has attempted to destroy evidence. **FFF. The Need to Prevent Other Harm** The defendant poses a significant risk of harm to others if released. She has been charged with serious crimes, including the sexual abuse of multiple minor victims, and has a history of violent behavior. **GGG. The Need to Prevent Flight** The defendant poses a significant risk of flight if released. She has a history of flight and has failed to comply with the terms of her pretrial release. **HHH. The Need to Prevent Obstruction of Justice** The defendant poses a significant risk of obstruction of justice if released. She has a history of lying to investigators and has attempted to destroy evidence. **III. The Need to Prevent Other Harm** The defendant poses a significant risk of harm to others if released. She has been charged with serious crimes, including the sexual abuse of multiple minor victims, and has a history of violent behavior. **JJJ. The Need to Prevent Flight** The defendant poses a significant risk of flight if released. She has a history of flight and has failed to comply with the terms of her pretrial release. **KKK. The Need to Prevent Obstruction of Justice** The defendant poses a significant risk of obstruction of justice if released. She has a history of lying to investigators and has attempted to destroy evidence. **LLL. The Need to Prevent Other Harm** The defendant poses a significant risk of harm to others if released. She has been charged with serious crimes, including the sexual abuse of multiple minor victims, and has a history of violent behavior. **MMM. The Need to Prevent Flight** The defendant poses a significant risk of flight if released. She has a history of flight and has failed to comply with the terms of her pretrial release. **NNN. The Need to Prevent Obstruction of Justice** The defendant poses a significant risk of obstruction of justice if released. She has a history of lying to investigators and has attempted to destroy evidence. **OOO. The Need to Prevent Other Harm** The defendant poses a significant risk of harm to others if released. She has been charged with serious crimes, including the sexual abuse of multiple minor victims, and has a history of violent behavior. **PPP. The Need to Prevent Flight** The defendant poses a significant risk of flight if released. She has a history of flight and has failed to comply with the terms of her pretrial release. **QQQ. The Need to Prevent Obstruction of Justice** The defendant poses a significant risk of obstruction of justice if released. She has a history of lying to investigators and has attempted to destroy evidence. **RRR. The Need to Prevent Other Harm** The defendant poses a significant risk of harm to others if released. She has been charged with serious crimes, including the sexual abuse of multiple minor victims, and has a history of violent behavior. **SSS. The Need to Prevent Flight** The defendant poses a significant risk of flight if released. She has a history of flight and has failed to comply with the terms of her pretrial release. **TTT. The Need to Prevent Obstruction of Justice** The defendant poses a significant risk of obstruction of justice if released. She has a history of lying to investigators and has attempted to destroy evidence. **UUU. The Need to Prevent Other Harm** The defendant poses a significant risk of harm to others if released. She has been charged with serious crimes, including the sexual abuse of multiple minor victims, and has a history of violent behavior. **VVV. The Need to Prevent Flight** The defendant poses a significant risk of flight if released. She has a history of flight and has failed to comply with the terms of her pretrial release. **WWW. The Need to Prevent Obstruction of Justice** The defendant poses a significant risk of obstruction of justice if released. She has a history of lying to investigators and has attempted to destroy evidence. **XXX. The Need to Prevent Other Harm** The defendant poses a significant risk of harm to others if released. She has been charged with serious crimes, including the sexual abuse of multiple minor victims, and has a history of violent behavior. **YYY. The Need to Prevent Flight** The defendant poses a significant risk of flight if released. She has a history of flight and has failed to comply with the terms of her pretrial release. **ZZZ. The Need to Prevent Obstruction of Justice** The defendant poses a significant risk of obstruction of justice if released. She has a history of lying to investigators and has attempted to destroy evidence. **AAA. The Need to Prevent Other Harm** The defendant poses a significant risk of harm to others if released. She has been charged with serious crimes, including the sexual abuse of multiple minor victims, and has a history of violent behavior. **BBB. The Need to Prevent Flight** The defendant poses a significant risk of flight if released. She has a history of flight and has failed to comply with the terms of her pretrial release. **CCC. The Need to Prevent Obstruction of Justice** The defendant poses a significant risk of obstruction of justice if released. She has a history of lying to investigators and has attempted to destroy evidence. **DDD. The Need to Prevent Other Harm** The defendant poses a significant risk of harm to others if released. She has been charged with serious crimes, including the sexual abuse of multiple minor victims, and has a history of violent behavior. **EEE. The Need to Prevent Flight** The defendant poses a significant risk of flight if released. She has a history of flight and has failed to comply with the terms of her pretrial release. **FFF. The Need to Prevent Obstruction of Justice** The defendant poses a significant risk of obstruction of justice if released. She has a history of lying to investigators and has attempted to destroy evidence. **GGG. The Need to Prevent Other Harm** The defendant poses a significant risk of harm to others