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Case 1:20-cr-00330-AJN Document 103 Filed 12/23/20 Page 10 of 15 The report shows nothing of the sort. Ms. Maxwell, who was sitting in a jail cell at the time, was asked by Pretrial Services to estimate her assets. Accordingly, she gave her best estimate of the assets she held in her own name, which the government concedes she did with remarkable accuracy considering that she had not reviewed her financial statements.” The government’s arguments further confirm that it has lost all objectivity and will view at any fact involving Ms. Maxwell in the worst possible light. For example, the government asserts that Ms. Maxwell has demonstrated “sophistication in hiding her assets” and characterizes her transfers to a trust as “funneling” assets to her spouse to “hide her true wealth.” (/d. at 24). There is nothing unusual, let alone nefarious or even particularly sophisticated about transferring assets into a trust or a spouse. Indeed, Ms. Maxwell fully disclosed these transactions on her joint tax returns. More importantly, all of the assets disclosed in the financial report, whether they are owned by Ms. Maxwell or her spouse, are included in the bond amount and are subject to forfeiture if she flees. The government further argues that the financial condition report shows that Ms. Maxwell has access to millions of dollars of “unrestrained funds” that she could use to flee the country and reimburse any of her sureties for the loss of their security. (/d. at 23). That characterization is simply untrue. First, as disclosed in the financial report, Ms. Maxwell has procured significant loans on the basis of a negative pledge over her London property. Second, the $4 million controlled by her spouse PO could only be liquidated with considerable difficulty. The government also faults Ms. Maxwell for not including a valuation of future contingent assets and income that may never materialize. (/d. at 23-24), For example, a ° Moreover, for the reasons discussed in our initial memorandum, Ms. Maxwell was reluctant to discuss anything about her spouse and clearly expressed her reluctance to Pretrial Services early on in the interview. DOJ-OGR-00002216