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Case 1:20-cr-00330-PAE Document171 Filed 03/23/21 Page /7of18 deprivation, and other conditions adverse to her physical health and mental well-being, Ms. Maxwell responded appropriately and accurately to questions posed by Pretrial Services which were restricted to her personal assets. Since then, financial documents - collected and professionally vetted by a highly respected accounting firm — have been submitted to the government and the Court and provide full details and supporting documentation concerning Ms. Maxwell’s personal assets and those jointly held with the spouse. Further, no valid challenge has been made to those submissions. The government challenges the Court by inanely stating that if “the only way to keep the defendant from using her assets to flee is to take away control of her assets, then she is too great a risk to release.” (Dkt.165 at 8.) This statement is fundamentally illogical as it undermines most conditions of release. For example, the same could be said of electronic monitoring — 1.e., if the only way to keep a defendant from fleeing the jurisdiction is to place him on home confinement with electronic monitoring, then he is too great a flight risk to release.* The Court should readily dismiss this frivolous argument. Under the Bail Reform Act, if there are appropriate conditions for release, bail should be granted. The conditions collectively proposed in the previous and present bail applications provide ample assurance that Ms. Maxwell will be present at trial. 3 Moreover, in an effort to further obfuscate the merits of Ms. Maxwell’s bail application, the government desperately argues that funds for legal services, presently held in attorney escrow accounts, would be released and made available to support Ms. Maxwell as a fugitive. To suggest that defense counsel would become accomplices to a violation of a court order shows utter disrespect for Ms. Maxwell’s defense team. In particular, New York counsel, who have spent the entirety of their legal careers practicing in this district and establishing well-respected reputations among the bench and bar, take umbrage at the government’s callous assertion. DOJ-OGR-00002787