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Case 21-770, Document 20-1, 04/01/2021, 3068530, Page10 of 31 indictment (which is, of course, true in every criminal case) and to the nature of the charges in the abstract. The district court bought into the government’s conclusory allegations, stating without support that: “(Mjindful of the presumption of innocence, the Court remains of the view that in light of the proffered strength and nature of the Government’s case, the weight of the evidence supports detention.” (emphasis added). The court fundamentally erred in relying on the government’s empty assertions that its case is strong. There was no principled way for the court to reach such a conclusion without hearing any evidence and without knowing anything at all about the allegations, especially here where the case is so old and based on anonymous hearsay which the defense has never been able to confront. The government did not even proffer that these anonymous accusers even made their claims under oath. Prosecutors refuse to disclose their names, their statements, the specifics of their allegations, or anything about them. This case is anything but strong. Ms. Maxwell should be granted bail or, at the very least, the case should be remanded for an DOJ-OGR-00000920