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Case 21-770, Document 20-1, 04/01/2021, 3068530, Page13 of 31 assets controlled and monitored by a former federal judge and former U.S. Attorney. She also cited the 12 pretrial motions she filed. “Without prejudicing the merits of any of those pending motions,” the judge again denied Ms. Maxwell’s motion for bail, relying in part on the “proffered strength and nature of the Government’s case,” even though, again, no evidence was actually submitted to or reviewed by the trial court. This appeal follows. In each of her bail requests and in separate pleadings, Ms. Maxwell has documented the Kafkaesque conditions that she is forced to endure. See, e.g., Ex.M. B. The pretrial motions Ms. Maxwell filed 12 substantial pretrial motions. Docs. 119-26; 133-48. These include motions to dismiss for violation of the statute of limitations (Docs. 143-44) and for pre-indictment delay (Docs. 137-38) because the conduct is so old. And to dismiss because the government violated the non-prosecution agreement it reached with Epstein that protected any alleged co-conspirator from prosecution. Docs 141-42. The government needed 212 pages to respond to these motions. These 11 DOJ-OGR-00000923