DOJ-OGR-00001226.jpg

CaGade2bter CT IZ0caohen Dete Gireh101 O20 2h | 6 6.2730) 26a Geaigeot 11 Ob 22 and secured by approximately $8 million in property and $500,000 in cash, along with six additional bonds—five co-signed by the Defendant’s friends and family members and the sixth posted by the security company that would provide security services to the Defendant if she were granted bail and transferred to home confinement. See Def. Mot. at 2. At the initial hearing, the Court noted that the opaqueness of the Defendant’s finances rendered it difficult to set financial bail conditions that could reasonably assure her appearance in court. The financial information that the Defendant presented to the Court at the initial bail hearing was undisputedly incomplete, and as the Court noted, the Court lacked “a clear picture of Ms. Maxwell’s finances and the resources available to her.” Tr. at 86 87. The Defendant has now presented to the Court what is perhaps a more thorough report on her finances prepared by Macalvins, an accounting firm in the United Kingdom. Macalvins analyzed the Defendant’s assets and finances for the past five years, basing its analysis on, among other things, bank statements, tax returns, and FBAR filings, providing a summary of the assets held by the Defendant and her spouse as well as the assets held in trust for the benefit of the Defendant for the period stemming from 2015 to 2020. See Def. Mot., Ex. O. In addition, the Defendant retained a Certified Fraud Examiner and a former IRS Special Agent, who reviewed the Macalvins report and the underlying documents and determined that report accurately represents the assets held by the Defendant and her spouse. See Def. Mot., Ex. P. The Defendant’s new bail proposal is based on the numbers derived from the Macalvins report. But even assuming that the financial report provides an accurate analysis of the Defendant’s finances, the Court is unpersuaded by her argument that the bail package reasonably assures her appearance. As the Government argues, the bail package would leave unrestrained 17 DOJ-OGR-00001226