DOJ-OGR-00006202.jpg

Case 1:20-cr-00330-PAE Document 423 Filed 11/08/21 Page2of11 Page 2 minor victims and the potential penalties those charges carry. (/d. at 82). Second, the Court determined that “[t]he government’s evidence at this early juncture of the case appears strong” based on the “multiple victims who provided detailed accounts of Ms. Maxwell’s involvement in serious crimes,” as well as corroboration in the form of “significant contemporaneous documentary evidence.” (/d.). Third, the Court found that the defendant’s history and characteristics demonstrate that she poses a risk of flight. (/d. at 83). In addressing that third factor, the Court emphasized the defendant’s “substantial international ties,” which “could facilitate living abroad,” including “multiple foreign citizenships,” “familial and personal connections abroad,” and “at least one foreign property of significant value.” (/d.). The Court noted that Maxwell “is a citizen of France, a nation that does not appear to extradite its citizens,” and found that Maxwell “possesses extraordinary financial resources,” yet “the representations made to Pretrial Services regarding the defendant’s finances likely do not provide a complete and candid picture of the resources available.” (/d. at 83-84). Accordingly, the Court found that the Government had carried its burden of demonstrating that the defendant “‘poses a substantial actual risk of flight” and that “even the most restrictive conditions of release would be insufficient” to ensure her appearance. (/d. at 86). The Court found that although Maxwell “apparently failed to submit a full accounting or even a close to full 99 66 accounting of her financial situation,” “[e]ven if the picture of her financial resources were not opaque, as it is, detention would still be appropriate.” (/d. at 86-87). That conclusion was informed by the defendant’s “significant financial resources” and “demonstrated sophistication in hiding those resources and herself.” (/d. at 87). The Court emphasized that the defendant’s “recent conduct underscores her extraordinary capacity to evade detection, even in the face of what the defense has acknowledged to be extreme and unusual efforts to locate her.” (/d.). The Court DOJ-OGR- 00006202