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Case 21-770, Document 57, 04/19/2021, 3080288, Page2 of 30 Appellant Ghislaine Maxwell’s Reply in Support of Her Motion for Pretrial Release The Government’s Response underscores why this Court should order bail for Ghislaine Maxwell so that she can prepare for trial. The court below erred in accepting the Government’s conclusory proffer without any actual evidence. And the conditions of her confinement make it impossible for her to effectively prepare her defense. The Government concedes that Ms. Maxwell is not a danger to the community, and her proposed bail package demonstrates that she is not a risk of flight. Accordingly, she should be released on bail. At the very least, this matter should be remanded to the district court to conduct a real bail hearing to (1) test the actual strength of the Government’s case, and (2) determine whether Ms. Maxwell should be eranted temporary release so that she can effectively prepare for trial, which she cannot do under the current conditions of confinement. Relying almost entirely on a regurgitation of quotations from the lower court (the first 26 of the 48-paragraph pleading is labeled “Facts”), only ten paragraphs, labeled “Discussion,” even attempt to address Ms. Maxwell’s arguments. As much as the Government would prefer that Ms. Maxwell not have a fair fight, this Court must level the playing field so DOJ-OGR-00001374