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ay Case 21-770, Document 20-2, 04/01/2021, 3068530, Page146 of 200 k7e2MaxC kjc legal de N Ww ws Oo OY ~] oO Ke) Ww a OY 20 21 22 23 24 25 agreement, and have been directly countered by Citations to law. matters at this stage, based on what's been asserted thus those arguments are asser Although the cour ted in a conclusory t does not prejudg they do not undermin th the bail determination stage. potential strength of arguments countering thes flight. Third, the court considers the det characteristics and Ms. strength of def Ms. finds that pa Maxwell poses a risk of nses, Maxwell is now aware of thus creating a risk of 83 fenses based on untimeliness and the nonprosecution fashion the government with thes far, the government's case at the the government's case against her and Fendant's history and ramount in a conclusion that Fligh substantial international ties an she were abroad if me) multiple connections abroad, An Significant value. France, citizens. Moreover, written submission and today, financia fl foreign citizenships, d, ] ee the Un ha in particular, d could ited States. S Ms. familial and and owns at least one Ms. extraordinary the coun means to flee Given th try despite COVI foreign property of Maxwell has facilitate living She holds personal she is a citizen of a nation that does not appear to extradite its as the government has detailed in its Maxwell possesses resources which could provide her the restriction. government's D-19-relat ted travel vidence, th court SOUTHERN STRICT R G! ‘PORT BRO, Ps (212) 805-0300 DOJ-OGR-00001087