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Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 31 of 91 31
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1 THE COURT: I'm sorry, Ms. Moe, if I may pause you
2 before moving on from those points.
3 There is a basic dispute within the papers as to, I
4 think, efforts similar to the ones you have described that are
5 efforts to hide from authorities, which would certainly be an
6 indication of risk of flight or whether, in light of the
7 notoriety and public interest that the case has generated
8 following the indictment of Mr. Epstein, whether it was an
9 effort to protect privacy and hide from press for privacy
10 reasons.
11 How does the government suggest that that factual
12 determination be resolved, if you agree that it should, and
13 what is your general response to the veracity of that
14 assertion?
15 MS. MOE: Yes, your Honor.
16 As we discussed in our reply brief, your Honor, in our
17 view, there is no question these circumstances are relevant to
18 the court's determination with respect to bail for a number of
19 reasons.
20 The first is, irrespective of the defendant's motive,
21 these facts make clear to the court that the defendant has the
22 ability to live in hiding, that she is good at it, that she is
23 willing to do it even if it compromises her relationship and
24 contacts with other people and, as the information provided by
25 the real estate agent underscores, she is good at it and that

SOUTHERN DISTRICT REPORTERS, P.C.

(212) 805-0300

DOJ-OGR-00001908