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Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 24 of 91 24
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1 legal presumption that there are no conditions that could
2 reasonably assure her return to court and, your Honor, the
3 defendant has not come anywhere close to rebutting that
4 presumption.
5 Turning first to the nature and seriousness of the
6 offense and the strength of the evidence, the indictment in
7 this case arises from the defendant's role in transporting
8 minors for unlawful sexual activity and enticing minors to
9 travel to engage in unlawful sexual active and participating in
10 a conspiracy to do the same. The indictment further charges
11 that the defendant perjured herself, that she lied under oath
12 to conceal her crimes.
13 Your Honor, the charged conduct in this case is
14 disturbing and the nature and circumstances of the offense are
15 very serious. The defendant is charged with participating in a
16 conspiracy to sexually exploit the vulnerable members of our
17 community. In order to protect the privacy of the victims, I'm
18 not going to go into details, your Honor, about the particular
19 victims beyond what's contained in the indictment and our
20 briefing; but, as the indictment alleges, the defendant enticed
21 and groomed girls who were as young as 14 years old for sexual
22 abuse by Jeffrey Epstein, a man who she knew was a predator
23 with a preference for underaged girls. The indictment alleges
24 that the defendant participated in some of these acts of abuse
25 herself, including sexualized massages in which the victims

SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300

DOJ-OGR-00001901