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Case 21-58, Document 58-1, 04/12/2021, 3075763, Page of 25 acknowledged to be extreme and unusual efforts to locate her.” (/d.).4 Judge Nathan concluded that electronic monitoring and private security guards “would be insufficient” because Maxwell could remove the monitor and evade private guards. (Id. at 87-88). She also rejected Maxwell’s comparison to certain other high-profile defendants, citing “crucial factual differences” in those cases. (/d. at 88). 15. Finally, Judge Nathan rejected Maxell’s arguments about the risks of COVID-19 and the difficulty of preparing a defense with an incarcerated client, noting that Maxwell had many months to prepare for trial and has no underlying conditions that place her at heightened risk of complications from COVID-19.° (/d. at 89-90). Judge Nathan found that measures in place were sufficient to ensure Maxwell’s access to her counsel, but also directed the Government to work with the defense “to provide adequate communication between counsel and client” and stated that the defense may make specific applications to the District Court for further relief if the process was “inadequate in any way.” (/d. at 90-91). * For example, Maxwell did not leave her home but had security guards make purchases for her using a credit card in the name of an LLC. Before her arrest, Maxwell ignored FBI agents’ directions to open the door and tried to flee to another room in the house. A cell phone was found wrapped in tin foil on top of a desk. See, e.g., Dkt. 22 at 7-8 (full version of Ex. C), Ex. D at 32-34. > Maxwell now has been fully vaccinated. (Gov’t Ex. A at 19, 21). 8 DOJ-OGR- 00020242