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Case 1:20-cr-00330-PAE Document 423 Filed 11/08/21 Page6of11 Page 6 The Court rejected the defendant’s argument that the strength of the evidence was diminished by her then-pending pre-trial motions (which have since been denied). (/d. at 5-6). The Court also rejected the two additional conditions proposed by the defendant, noting the “Tclonsiderable uncertainty regarding the enforceability and practical impact of the [foreign citizenship] renunciations,” and finding that, despite the proposed monitorship, the defendant “would continue to have access to substantial assets—certainly enough to enable her flight and to evade prosecution.” (/d. at 10-11). The Court concluded, “If the Court could conclude that any set of conditions could reasonably assure the Defendant’s future appearance, it would order her release. Yet while her proposed bail package is substantial, it cannot provide such reasonable assurances.” (/d. at 11). 4. The Second Circuit’s Orders The defendant filed appeals from the Court’s second and third detention orders. After hearing oral argument, the Circuit denied the defendant’s motion for bail in a written order. (See United States v. Maxwell, No. 21-58, Dkt. 86 (2d Cir. Apr. 27, 2021)). Following that decision, the defendant submitted a letter to this Court asking it “to address Ms. Maxwell’s sleeping conditions by directing MDC to cease 15-minute light surveillance of Ms. Maxwell or justify the need for the disruptive flashlight surveillance.” (Dkt. 256 at 2). The Court promptly ordered the Government to confer with MDC counsel and provide the Court with an explanation regarding the use of flashlights and the basis for it, which the Government then did. (Dkt. 257, 270). On May 14, 2021, this Court issued an order denying the defendant’s request for an order directing the MDC to modify its nighttime monitoring schedule. (Dkt. 282). In reaching this decision, the Court noted that the defendant’s claim that MDC staff were shining the light directly into her eyes and disrupting her sleep was “unsupported by affidavit or other factual DOJ-OGR-00006206