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Caseabe? @-cS60BRGUURnt Dbctindé rf 1/26 2 FileebR230/Rag Paget Sof 22 does not mean that those people would be unable to visit her were she to flee to another country. In addition, the Defendant continues to lack any employment ties to the United States—another factor weighing in favor of detention. Furthermore, it is apparent from the letters that the Defendant has significant ties to family and friends abroad. In light of this, nothing in the renewed motion for bail alters the Court’s fundamental conclusion that flight would not pose an insurmountable burden to the Defendant. Other factors that similarly speak to the Defendant’s history and characteristics weigh in favor of detention. Most notably, the Defendant’s pattern of providing incomplete or erroneous information to the Court or to Pretrial Services bears significantly on the Court’s application of the third factor to the present case. Among other things, in July 2020 the Defendant represented to Pretrial Services that she possessed around $3.5 million worth of assets (while leaving out her spouse’s assets and assets that had been transferred to trust accounts) and the representation that the New Hampshire property was owned by a corporation and that she was “just able to stay there.” See Pretrial Services Report at 2. The Defendant now claims that she “was detained at the time and had no access to her financial records and was trying to piece together these numbers from memory. According to the Macalvins report, |the financial figures| are a close approximation of the value of the assets that Ms. Maxwell held in her own name at the time of her arrest... . For the reasons already discussed, Ms. Maxwell was reluctant to discuss anything about her |spouse| and expressed that to Pretrial Services.” Def. Mot. at 16 n.5. Even if the Defendant was unable to provide an exact number, however, the difference between the number she originally reported to Pretrial Services and the number now presented to the Court in the Macalvins report, a report on the Defendant’s finances prepared by a prominent accounting firm for purposes of this motion, see Def. Mot., Ex. O, makes it unlikely that the misrepresentation 15 DOJ-OGR-00020142