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Case 1:20-cr-00330-PAE Document171 Filed 03/23/21 Page2of18 Preliminary Statement The issue before the Court, as it has been since Ms. Maxwell’s first bail application, is whether conditions exist that can reasonably assure Ms. Maxwell's appearance at trial. On her third application (the “Third Bail Motion”) (Dkt.160), Ms. Maxwell has put before the Court significant enhancements to the already extraordinary bail package previously presented to the Court in her renewed application for bail (the “Second Bail Motion’’) (Dkt. 97).! Together, these two motions present a unique and comprehensive bail package with the strictest of conditions known in any bail application: = $28.5 million in bonds (including a $1M bond co-signed by a security company); = $9.5 million in real property; = $550,000 in cash; = Asset Monitoring by a retired federal district court judge; = Renunciation of British and French citizenship; = Irrevocable written waivers of the right to contest extradition; =" Surrender of all travel documents; = Home confinement in New York City; = Electronic GPS monitoring; " Jn-residence third-party custodian;7 ' Ms. Maxwell’s present motion (the “Third Bail Motion”) (Dkt.160) incorporates her Memorandum in Support of Her Renewed Motion for Bail and accompanying exhibits (Dkt. 97, including Attachments 1-24) and her Reply Memorandum in Support of Her Renewed Motion for Bail (Dkt. 103, including Attachments 1-2) (collectively, the “Second Bail Motion’). 2 To assist Ms. Maxwell in making up for lost time preparing for her upcoming trial, one of her lawyers (not trial counsel) has agreed to reside with her and serve as an additional residential custodian. DOJ-OGR- 00002782