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Case 21-58, Document 39-1, 04/01/2021, 3068530, Page29 of 31 The Supreme Court has explained that when “the Government has admitted that its only interest is in preventing flight, bail must be set by a court at a sum designed to ensure that goal, and no more.” The government simply has not come close to satisfying its heavy burden of proving that “no conditions” exist that will reasonably assure Ms. Maxwell’s presence. It has not articulated with any evidence, let alone specific and credible evidence, how Ms. Maxwell could manage to flee under the proposed bail conditions. Speculation is not permitted. United States v. Bodmer, No. 038-cr-947(SAS), 2004 WL 169790 (S.D.N.Y. Jan. 28, 2004) (where government’s argument that no conditions could assure defendant’s future presence was based, “in large part, on speculation,” defendant was released to home confinement with GPS monitoring). We challenge the government to point to a high profile defendant who in the recent past has 1) fled and 2) gotten away with it. The reality is that defendants with far greater likelihood of conviction than Ms. Maxwell are granted bond and appear in court. Ms. Maxwell should not be treated differently. 27 DOJ-OGR-00019857