DOJ-OGR-00010453.jpg

Case 1:20-cr-00330-PAE Document 663 Filed 06/15/22 Page 7 of 77

at the beach; and her husband, who was besieged by media coverage and had lost his employment and professional relationships. Ms. Maxwell was also worried for herself, having legitimate reason to fear for her own life.

Despite having the benefits of foreign citizenship, Ms. Maxwell, a naturalized American citizen, remained in the United States consistently after Epstein’s death, never evading the authorities. At the time of her arrest, Ms. Maxwell was not considering flight – even though, given her French and British nationalities, she could have taken refuge in these and other countries at any time. Law enforcement had been discreetly keeping tabs on her throughout the course of its investigation.⁵ Her lawyers had been in contact with prosecutors in the months preceding her arrest and would have arranged for her self-surrender. Ms. Maxwell’s presence in New Hampshire was driven solely by the need to protect herself and her family from threats of physical harm and from the unprecedented and escalating press and public vilification she had to endure since Epstein’s death.

On July 6, 2020, exactly a year to the day after Epstein’s arrest, Ms. Maxwell was ordered detained in the Metropolitan Detention Center (“MDC”) based on the government’s assertion that she posed “an extreme risk of flight” and that “no condition or combination of conditions will reasonably assure the appearance of the defendant as required.”⁶ Each of four bail applications were denied on the elusive claim of flight risk, despite the unprecedented financial collateral and restrictions proposed to secure a hefty bond for an almost 60-year-old woman who, the government conceded, posed no danger to the community, and who had never attempted to flee the United States. For the next 22 months she was exposed to discriminatory and punitive solitary

⁵ https://www.youtube.com/watch?v=E7J4ReLHvqg, at 2:31- 2:39.

⁶ 20 Cr. 330, Dkt. 4, at 2.

6

DOJ-OGR-00010453