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CaSeast:20-O8008Q0HAENt ISSeUMEht B02 FileeHhAIA/ Pag Page af126i45 B. Ms. Maxwell Has Provided a Thorough Review of Her Finances for the Past Five Years The government raised concerns at the initial bail hearing about the accuracy and completeness of the financial disclosures that Ms. Maxwell provided to Pretrial Services. (Dkt. 22 at 11-12: Tr. 28-29, 34-35). The Court stated that it did not have “a clear picture of Ms. Maxwell's finances and the resources available to her” and therefore had no way “to set financial bail conditions that could reasonably assure her appearance in court.” (Tr. 86-87). To address the Court’s questions about Ms. Maxwell’s finances, defense counsel retained Macalvins, a highly reputable accounting firm in the United Kingdom, to conduct an analysis of Ms. Maxwell’s assets and finances for the past five years. The Macalvins accountants reviewed thousands of pages of financial documents, including bank statements, tax returns, FBAR filings, and other materials to create a clear picture of the assets held by Ms. Maxwell and her spouse, as well as any assets held in trust for the benefit of Ms. Maxwell, and the source of those assets from 2015-2020. This analysis, which is based in substantial part on documents that the government provided in discovery, has involved a significant amount of work and has taken substantial time to complete. It was not possible to perform this analysis in the brief time between Ms. Maxwell’s arrest and the initial bail hearing, especially with Ms. Maxwell detained following her arrest. The Macalvins report was also reviewed _y iii. a Certified Fraud Examiner and a former IRS Special Agent with over 40 years of experience in complex financial fraud investigations. As a Special Agent, | investigated numerous financial fraud and criminal tax cases, including several in this District. Dl reviewed the Macalvins report and the underlying documents and determined that it presents a complete and accurate summary of the assets held by Ms. Maxwell and her spouse, as well as assets that were, or are currently, held in DOJ-OGR-00020035