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be N Ww ws Oo OY ~] oO Ke) Ww a OY 20 21 22 23 24 25 Case 21-58, Document 39-2, 04/01/2021, 3068530, Page145 of 200 k7e2MaxC kjc quoting there Cir. 2019). The court concludes as First, the here weigh in favor of involving minor victims that Ms. are serious enough detention. And of innocent until proven guilty, th sentences sh to reiterate, bu from United States v. Boustani, nature and circumstances of detention. 932 F.3d 79, (2d follows: the offense As noted, the crimes Maxwell has been accused of to trigger a statutory presumption in favor Ms. Maxwell is presumed she were convicted of if these crimes, incentivize her to flee. years old, And even if In total, faces up to a 35-year maximum term of sentences ar faces is substantial enough to Ms. Maxwell, who is 58 imprisonment she convicted. if would still Second, the full presumption of th consider strength of government in assessing risk e) face up to a decade o noting again that innocence, the evidence pro run concurrently, f incarceration. Ms. Maxwell is entitled to it is appropriate to Ffered by the Flight. The government's evidence at this early juncture of Although the charged conduct took place many years ago, the case appears strong. the indictment accounts of Ms. government also pro Maxwell's involvement in serious crimes. describes multiple victims who provided detailed The ffers that this witness testimony will be corroborated by significant contemporaneous documentary evidence. While the defense states that it intends to assert SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 82 DOJ-OGR- 00020004