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Case 1:20-cr-00330-AJN Document 97 Filed 12/14/20 Page 23 of 45 2020, other than daily living expenditures for her family and for professional services in the defense of Ms. Maxwell from the charges she faces. (/d. § 16). The Macalvins report confirms that Ms. Maxwell disclosed all of her foreign bank accounts in FBAR filings and properly disclosed her bank accounts, investments and other assets in her US. tax filings at all times. (Ud. §] 25, 30). The report also explains that the transfers of funds between various accounts in the past few years, which the government highlighted in their initial bail submission (Dkt. 22 at 11-12), reflected movements between banks triggered by the closure of one banking relationship and the opening of new relationship, as well movements of cash maturing on deposit and other financial investments. (/d. § 18). At the last bail hearing, the government suggested that Ms. Maxwell’s finances were “opaque” and that she potentially had “significant [] undetermined and undisclosed wealth.” (Tr. 27; Dkt. 22 at 11-12). The Macalvins report lifts this cloud of unjustified intrigue and provides a straightforward answer: Ms. Maxwell and her spouse currently have assets worth approximately $22.5 million.© Accordingly, the proposed bond amount of $22.5 million represents all of the couple’s current assets. The report further shows that Ms. Maxwell has no undisclosed wealth and is not hiding assets overseas. To the contrary, for the past several years, Ms. Maxwell and her husband have disclosed their foreign assets by submitting FBAR filings regarding their ° We have redacted the name of the bank where though the alance of the account 1s fully disclosed m the Macalvins report, we felt it necessary to redact the name of the bank , of course, follow the Court’s to the Court and the government, if required. In that event, we ask that the Court establish guidelines limiting what the government can do with the information. 17 DOJ-OGR-00001995