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Case 21-770, Document 20-2, 04/01/2021, 3068530, Page151 of 200 k7e2MaxC kjc 88 1 start. Likewise, the possibility that Ms. Maxwell could evade 2 security guards or monitoring is a significant one. 3 The court finds by a preponderance of the evidence 4 that no combination of conditions could reasonably assure her 5 presence in court. The risks are simply too great. 6 Defense cites a number of cases, including Esposito, 7 Dreier, and Madoff, as examples of serious and high-profile 8 prosecutions where the courts, over the government's objection, 9 granted bail to defendants with significant financial 10 resources. But unlike those defendants, Ms. Maxwell possesses 11 significant foreign connections. 12 This case is distinguishable for other reasons, as 13 well. For example, the risk of flight in Esposito appears to 14 have been based on the resources available to defendant, not 15 foreign connections or experience and a record of hiding from 16 being found. 17 In Madoff, the defendant had already been released on 18 a bail package agreed to by the parties for a considerable 19 period of time before the government sought detention. The 20 court there found there were no circumstances in the 2] intervening period showing that the defendant had become a 22 flight risk. Because of these crucial factual differences, the 23 court finds the cases not on point and not persuasive. 24 Finally, in arguing for release, the defense raises 25 the challenges and risks posed by the COVID-19 pandemic. The SOUTHERN DISTRICT RE PORTERS, P.C. (212) 805-0300 DOJ-OGR-00001092