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Case 1:20-cr-00330-AJN Document 97 Filed 12/14/20 Page 11 of 45

contest extradition in both the United Kingdom and France.² We also provide opinions from experts in the extradition laws of the France and the United Kingdom stating that it is highly unlikely that Ms. Maxwell would be able to resist extradition from either country in the event she were granted bail and somehow fled to either country, which she has no intention of doing. Their opinions also state that any extradition proceeding would be resolved promptly. (Exs. T-V).

• Lack of corroborating evidence. The government represented to the Court that it had "contemporaneous documents," including "diary entries" in support of its case. (Dkt. 4 at 5). The defense has now reviewed the discovery produced to date, including all of the documents that the government described as the core of its case against Ms. Maxwell. As explained more fully below, the discovery contains no meaningful documentary corroboration as to Maxwell and only a small number of documents from the time period of the conspiracy charged in the indictment. As an example, the government produced only [REDACTED]³
The evidence in this case boils down to witness testimony about events that took place over 25 years ago. Far from creating a flight risk, the lack of corroboration only reinforces Ms. Maxwell's conviction that she has been falsely accused and strengthens her long-standing desire to face the allegations against her and clear her name in court.

• Oppressive conditions of confinement. Ms. Maxwell has now been detained for over 150 days in the equivalent of solitary confinement since she was indicted and arrested on July 2, 2020, despite the fact that she is not a suicide risk and has not received a single disciplinary infraction. The draconian conditions to which Ms. Maxwell is subjected are not only unjust and punitive, but also impair her ability to review the voluminous discovery produced by the government and to participate meaningfully in the preparation of her defense. Furthermore, the recent COVID-19 outbreak at the MDC threatens her safety and well-being.

Ms. Maxwell Should Be Placed on Restrictive Bail Conditions

During her more than five months in isolation, Ms. Maxwell has had to watch as she has been relentlessly attacked in a deluge of media articles that spiked over a year ago when Epstein

² Ms. Maxwell has not yet signed these waivers because we have not been able to visit her in the MDC to obtain her signature since she was quarantined over two weeks ago. She will sign them as soon as legal visits resume.
³ In a letter dated October 13, 2020, we asked the government to provide additional discovery including, among other things, [REDACTED]
In light of the serious Brady infractions in recent cases before this Court, and the recent order filed in this case pursuant to Rule 5(F) of the Federal Rules of Criminal Procedure (see Dkt. 68), the government's failure to obtain [REDACTED] is curious and concerning.

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