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Case 1:20-cr-00330-AJN Document 103 Filed 12/23/20 Page 9 of 15 mistaken. Prior to her arrest, Ms. Maxwell and her spouse had discussed the idea of getting a divorce as an additional way to create distance between Ms. Maxwell and her spouse to protect tm | from the terrible consequences of being associated with her. Nevertheless, in the weeks following the initial bail hearing, Po PO She and her spouse therefore had no reason to continue discussing divorce, which neither of them wanted in the first place. Nor was there any reason for her spouse to refrain from stepping forward as a co-signer. In sum, the government has offered nothing but unsupported innuendo to suggest that Ms. Maxwell’s relationship with her spousc i is not a powerful tie to this country. The government’s assertion that Ms. Maxwell must not have a close relationship hr jury callous and belied by the facts. (Gov. Mem. at 14). As her spouse explains, | —SY ES 5), B. Ms. Maxwell Has Thoroughly Disclosed Her Finances and Pledged All of Her and Her Spouse’s Assets in Support of Her Bond The government’s attempts to rebut the financial condition report are unavailing. Significantly, the government does not contest the accuracy of the report, nor the voluminous supporting documentation. In fact, the government has proffered nothing that calls into question the report’s detailed account of Ms. Maxwell and her spouse’s assets for the last five years, which addresses one of the Court’s principal reasons for denying bail. Rather than question the report itself, the government attempts to argue that Ms. Maxwell deceived the Court and Pretrial Services about her assets. (Gov. Mem. at 22-23). DOJ-OGR-00002215