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Case 1:20-cr-00330-AJN Document 160 Filed 02/23/21 Page 3 of 9 citizens of those countries. The latter condition will restrain Ms. Maxwell’s assets so they cannot be used for flight or harboring her outside of the jurisdiction of this Court. This should satisfy the Court’s concern that the proposed bond was not fully secured and left assets unrestrained that could be used for such purposes. (See id. at 17-18). In addition, since the last bail application, Ms. Maxwell has submitted twelve pretrial motions that raise substantial legal and factual issues that may result in the dismissal of some or all of the charges against her. Ms. Maxwell referenced some of these motions in her initial bail application (see Dkt. 18 at 19) but was not in a position to fully articulate them until she had the chance to review the discovery and research the legal issues in advance of the motion deadline of January 25. These motions significantly call into question the strength of the government’s case against Ms. Maxwell and the underlying justification for continued detention. Ms. Maxwell has already been denied a fair chance in the court of public opinion. She has been maligned by the media, which has perpetuated a false narrative about her that has poisoned any open-mindedness and impartiality of a potential jury. She has been relentlessly attacked with vicious slurs, persistent lies, and blatant inaccuracies by spokespeople who have neither met nor spoken to her. She has been depicted as a cartoon-character villain in an attempt to turn her into a substitute replacement for Jeffrey Epstein. Yet, Ms. Maxwell is determined — and welcomes the opportunity — to face her accusers at trial and clear her name. The additional proposed bail conditions should quell any concerns that she would try to flee. The Court should therefore grant bail under the proposed conditions so that Ms. Maxwell can adequately prepare for trial. DOJ-OGR- 00002734