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Case 21-770, Document 20-1, 04/01/2021, 3068530, Page9 of 31

while the just added accuser involves allegations from 2001-04.³ That the indictment exists at all is a function – solely – of the untimely death of Jeffrey Epstein and the media frenzy that followed. The indictment against Ms. Maxwell was brought only in the search for a scapegoat after the same U.S. Attorney’s Office had to dismiss its case against Epstein because of his death at MCC. If there truly was any case against Ms. Maxwell, she would have been charged with Epstein in the SDNY in 2019. But she was not. She also was not charged – or even named – in the 2008 Epstein case in Florida. She would never be facing charges now if Epstein were alive.

Although there have been a number of orders related to bond in this case, the district court held only one detention hearing. At that hearing the government stated that Ms. Maxwell was a flight risk and that its case was strong. But it did not proffer any actual evidence in support of its contention, or the district court’s conclusion, that the weight of the evidence against Maxwell was strong. Ex.A. Instead, it pointed again and again only to the fact that the grand jury returned an

³ The government superceded the indictment on March 29, just months before the July trial, adding two counts involving a fourth anonymous accuser.

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