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Case 21-58, Document 76, 04/19/2021, 3080288, Page9 of 30 before this Court. 7. Ms. Maxwell is not suggesting that “any defendant in a case with voluminous discovery must be released on bail to prepare for trial.” Resp.940. Her case and situation is unique. Other defendants may pose a danger to the community. The Government concedes that she does not. Other defendants may not be U.S. citizens. She is. Other defendants may not have strong U.S. connections. Ms. Maxwell has lived here for 30 years, has a husband and step-children here, and has two sisters who are U.S. citizens and live here. Other defendants may not have pledged almost all of their assets or offer to have a monitor track her expenses. Ms. Maxwell has. Other defendants may not be willing to renounce their foreign citizenship. She is. Other defendants may have prior convictions. She does not. But other defendants have no connection to Jeffrey Epstein, and she does. Although unstated, that old connection is the driving factor for detention, and that is error. 8. The Government says that the district judge has “closely monitored” her conditions of confinement. Unfortunately, that is not accurate. The District Court accepted, without any real inquiry, the self-serving Government letters. These letters describe a “prison DOJ-OGR-00020299