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Case 1:20-cr-00330-AJN Document 97 Filed 12/14/20 Page 9 of 45 company has confirmed that they have never done this for any client, and that he is willing to do so for Ms. Maxwell because he is confident that she will not try to flee. * Ms. Maxwell will remain in the custody of a USS. citizen who has lived in the United States for 40 years. will serve as Ms. Maxwell’s third-party custodian under 18 U.S.C. § 3142(c)(1)(B)() and will live with Ms. Maxwell in a residence in New York City until this case has concluded. We have identified an appropriate residence in the Eastern District of New York that has been cleared by Ms. Maxwell’s security company. ¢ Travel restricted to the Southern and Eastern Districts of New York, and limited as necessary to appear in court, attend meetings with counsel, and visit with doctors/psychiatrists/dentists, and upon approval by the Court or Pretrial Services. ¢ Surrender of all travel documents with no new applications. ¢ Ms. Maxwell will provide the Court irrevocable written waivers of her right to contest extradition in France and the United Kingdom. ¢ Strict supervision by Pretrial Services. * Home confinement at her residence with electronic GPS monitoring. ¢ Visitors to be approved in advance by Pretrial Services, with counsel and family members to be pre-approved. ¢ Such other terms as the Court may deem appropriate under 18 U.S.C. § 3142. For her own safety, Ms. Maxwell will also have on-premises security guards 24 hours a day, 7 days a week. The security guards will prevent Ms. Maxwell from leaving the residence at any time without prior approval by the Court or Pretrial Services and will escort her when she is authorized to leave. If the Court wishes to make private security a condition of her bond, the guards could report to Pretrial Services.’ We believe these conditions are more than sufficient to reasonably assure Ms. Maxwell’s presence in court. ' As we argued in our initial bail application, this case involves the limited circumstance under which the Second Circuit approved granting pretrial release to a defendant on the condition that she pays for private armed security guards. United States v. Boustani, 932 F.3d 79, 82 (2d Cir. 2019) (defendant who “is deemed to be a flight risk primarily because of [her] wealth . . . may be released on such a condition only where, but for [her] wealth, [s]he would not have been detained” (emphasis in original)). Therefore, Ms. Maxwell may be released on the condition that she pay for private armed security. (Dkt. 18 at 20 n.16.) DOJ-OGR-00001981