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Case 21-58, Document 58-1, 04/12/2021, 3075763, Page23 of 25 five hours of video-teleconference calls with her counsel every weekday. (Gov’t Ex. A at 18). 40. Given these accommodations, Maxwell’s argument amounts to a suggestion that any defendant in a case with voluminous discovery must be released on bail to prepare for trial, regardless of flight risk or danger to the community. That cannot be the law. Rather, “[i]n considering whether there is a ‘compelling reason’ for a defendant’s release under [Section 3142(1)], a court must balance the reasons advanced for such release against the risks that were previously identified and resulted in an order of detention.” United States v. Chambers, No. 20 Cr. 135 (JMF), 2020 WL 1530746, at *1 (S.D.N.Y. Mar. 31, 2020). Here, that balance emphatically favors detention, given Judge Nathan’s repeated findings about risk of flight and the substantial accommodations made to ensure Maxwell’s ability to prepare her defense. 41. The risks presented by COVID-19 do not alter this conclusion. Not only does Maxwell have no underlying conditions that place her at heightened risk of complications from COVID-19 (Ex. D at 89-90; Ex. H at 21), but she now has been fully vaccinated (Gov’t Ex. A at 19, 21). And while some district courts have ordered temporary release based in part on the COVID-19 pandemic, each of these discretionary decisions rests on its particular facts, as Judge Nathan was well- 23 DOJ-OGR-00020257