DOJ-OGR-00019947.pdf

Case 21-58, Document 39-2, 04/01/2021, 3068530, Page88 of 200 1 were sometimes partially or fully nude. She also encouraged 2 these minors to engage in additional acts of abuse with Jeffrey 3 Epstein. The indictment makes plain, your Honor, this was not 4 a single incident or a single victim or anything isolated but, 5 instead, it was an ongoing scheme to abuse multiple victims for 6 a pattern of years. This is exceptionally serious conduct. 7 8 Given the strength of the government's evidence and 9 the serious charges in the indictment, there is an incredibly 10 strong incentive for the defendant to flee, an incentive for 11 her to become at that fugitive to avoid being held accountable 12 and to avoid a lengthy prison sentence. 13 The history and characteristics of the defendant 14 underscores the risk of flight that she poses. The Pretrial 15 Services report confirms that the defendant has been moving 16 from place to place for some time, your Honor; and most 17 recently it appears that she spent the last year making 18 concerted efforts to conceal her whereabouts whilst moving 19 around New England, most recently to New Hampshire, which I 20 will discuss momentarily with respect to that particular -- 21 THE COURT: Ms. Moe? 22 MS. MOE: -- property. 23 THE COURT: Ms. Moe, there is one assertion in the 24 defense papers that I don't think I have seen the government's 25 response to, and that is the contention that Ms. Maxwell, through counsel, kept in touch with the government since the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00019947