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Case 1:20-cr-00330-AJN Document 122 Filed 12/28/20 Page 12 of 36

defendant faces up to 35 years of incarceration, and may very well spend the remainder of her
natural life in prison. The seriousness of the offenses make such a steep penalty a real possibility
upon conviction, thereby giving the defendant an overwhelming incentive to flee if given the
chance.

In light of that strong incentive to flee, all three of the victims listed in the Indictment have
asked the Government to convey to the Court that they continue to seek the defendant’s detention.
Additionally, pursuant to the Crime Victims’ Rights Act, one of the victims has provided a written
statement urging the Court to deny bail, which is attached as Exhibit A hereto. That unanimous
view of the victims reflects three related reasons that this factor weighs so heavily in favor of
detention. First, the victims sincerely fear that if the defendant is released, she will be able to
evade justice. Second, the pain that the victims still feel to this day as a result of the defendant’s
conduct supports the conclusion that this offense is especially serious and may result in a lengthy
sentence. Third, as discussed further below, the victims’ attention to this case and willingness to
convey their views reflects their commitment to take the stand and testify at the defendant’s trial,
demonstrating the strength of the Government’s case.

In short, this factor offers no reason to reverse the prior detention order.

B. The Strength of the Evidence

Further incentivizing the defendant to flee, the Government’s evidence remains strong. As
the Court recognized when analyzing this factor at the July 14, 2020 hearing, the central evidence
in the Government’s case will come from the detailed testimony of three different victims, who
will each independently describe how the defendant groomed and enticed them to engage in sexual
activity with Jeffrey Epstein. (Tr. 82). The Indictment itself contains a description of the accounts
these victims have provided law enforcement, which corroborate each other in meaningful part.

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