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Case 21-770, Document 20-1, 04/01/2021, 3068530, Page12 of 31 The court said it was detaining Ms. Maxwell, in part, because the government proffered that its “witness testimony will be corroborated by significant contemporaneous documentary evidence.” Ex.D at 82. The court also pointed to Ms. Maxwell’s lack of “significant family ties” in the United States, her unclear financial picture, the “circumstances of her arrest,” and that although she is a U.S. citizen, she is also a citizen of France and Britain. Jd. at 82-87. Ms. Maxwell filed a second motion for bail and addressed each of these concerns. Ex.E. For starters, the defense explained that none of anonymous accusers’ testimony of abuse was corroborated and that it all related to Epstein, not Ms. Maxwell. In addition, Ms. Maxwell does have significant ties to the United States, her assets were thoroughly disclosed and vetted, and she is willing to waive extradition. The government responded. Ex.F. The defense replied. Ex.G. The judge again denied bail, relying, for the second time, on the “strong” evidence, even though no evidence was presented to the court to rely on.4 Ms. Maxwell filed a third motion for bail. Ex.I. In this application, she offered to renounce her foreign citizenship and also to have her 4 Ms. Maxwell filed a notice of appeal from this Order, which is docketed in Case No. 21-58. 10 DOJ-OGR-00000922