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Case 21-770, Document 20-2, 04/01/2021, 3068530, Page149 of 200 k7e2MaxC kjc 86 1 incentive she had before this indictment may very well have 2 changed after it. In other words, her federal indictment may 3 well change her earlier decisions and, given the defendant's 4 resources, the court concludes that Ms. Maxwell poses a 5 substantial actual risk of flight. 6 Having made this determination, the court next turns 7 to whether the government has met its burden to show by a 8 preponderance of the evidence that no combination of conditions 9 could reasonably assure the defendant's presence. The court is 10 persuaded that the government has met this burden and concludes 11 that even the most restrictive conditions of release would be 12 insufficient. 13 As an initial matter, the financial component of 14 Ms. Maxwell's proposed bail package appears to represent a 15 relatively small component of the access available to her and 16 is secured only by a foreign property said to be worth about 17 several million dollars. But even a substantially larger 18 package would be insufficient. The extent of her financial 19 resources is demonstrated by some of the transactions and bank 20 accounts discussed in the government's submission and here 21 today, and Ms. Maxwell has apparently failed to submit a full 22 accounting or even a close to full accounting of her financial 23 Situation. She has provided the court with scarce information 24 about the financial information of her proposed cosigners, for 25 example. Without a clear picture of Ms. Maxwell's finances and SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00001090