DOJ-OGR-00020009.pdf

--- Page 1 --- **Document Header:** * Case 21-58, Document 39-2, 04/01/2021, 3068530, Page150 of 200 **Page Number:** * 87 **Text:** 1. the resources available to her, it is practically impossible to 2. set financial bail conditions that could reasonably assure her 3. appearance in court. 4. Even if the picture of her financial resources were 5. not opaque, as it is, detention would still be appropriate. 6. Personally, the defendant not only has significant financial 7. resources, but has demonstrated sophistication in hiding those 8. resources and herself. After the arrest of Jeffrey Epstein, 9. Ms. Maxwell retreated from view. She moved to New England, 10. changing locations on multiple occasions, and appears to have 11. made anonymous transactions both big and small. The defense 12. said that she did all of this not to hide from the government 13. but to maintain her privacy and avoid public and press 14. scrutiny. Even assuming that Ms. Maxwell only wanted to hide 15. from the press and public, an assumption that the court does 16. not share, but even assuming that's the case, her recent 17. conduct underscores her extraordinary capacity to evade 18. detection, even in the face of what the defense has 19. acknowledged to be extreme and unusual efforts to locate her. 20. Because of these concerns, even a bail package with 21. electronic monitoring and home security guards would be 22. insufficient. Were she to flee, the defendant could simply 23. remove the monitoring bracelet and, as other courts have 24. observed, home detention with electronic monitoring does not 25. prevent flight. At best it limits a fleeing defendant's head **Footer:** * SOUTHERN DISTRICT REPORTERS, P.C. * (212) 805-0300 * DOJ-OGR-00020009