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Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 9 of 19

make purchases for the property using the credit card. As these facts make plain, there should be no question that the defendant is skilled at living in hiding.

The defendant asks the Court to ignore many of the obvious indicators of a flight risk by arguing that she has lived in hiding because of unwanted press attention. This argument entirely misses the point. First, the defendant’s conduct is clearly relevant to the Court’s assessment of her risk of flight, because it evidences her readiness and ability to live in hiding, and to do so indefinitely. As such, even if her behavior in the last year could be attributed solely to her desire to avoid media attention, that should give the Court serious concerns about what steps she would be willing to take to avoid federal prison. Second, the fact that the defendant took these measures to conceal herself after Epstein was indicted in this District – and after the Government announced that its investigation into Epstein’s co-conspirators was ongoing – cannot be ignored. To the contrary, these measures are at least equally consistent with the notion that the defendant also sought to evade detection by law enforcement.

In attempting to sidestep the evidence of her ability and willingness to hide, the defendant points to her decision to remain in the United States for the past year while the Government’s investigation remained ongoing. She claims that because she did not flee the country during an ongoing investigation, she will not do so while under indictment. This argument ignores the world of difference between believing that an investigation is ongoing and being indicted in six counts by a federal grand jury. The defendant now faces the reality of serious charges, supported by significant evidence, and the real prospect of spending many years in prison. The return of the indictment fundamentally alters the defendant’s incentives and heightens the incentive to flee far beyond the theoretical possibility of a charge during an investigation (one the defendant may have wrongly believed would or could not reach her). That is especially so when the defendant has

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