court filing: 20-cr-80038

The government argues that the defendant is a flight risk due to her ability to live in hiding and her history of concealing herself, particularly after Epstein's indictment. The defendant's argument that she has not fled the country during the investigation is not persuasive, as the return of the indictment significantly increases her incentive to flee. The government contends that the defendant's conduct is relevant to assessing her risk of flight.