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Case 21-770, Document 20-1, 04/01/2021, 3068530, Page15 of 31 STANDARD OF REVIEW The question of whether a bail package will reasonably assure the defendant’s presence is a mixed question of law and fact. United States v. Horton, 653 F. App’x 46, 47 (2d Cir. 2016). This Court reviews the district court’s purely factual findings for clear error. Jd. However, the district court’s ultimate finding “may be subject to plenary review if it rests on a predicate finding which reflects a misperception of a legal rule applicable to the particular factor involved.” Id. at 319-20 (quoting United States v. Shakur, 817 F.2d 189, 197 (2d Cir. 1987)). That is, “even if the court’s finding of a historical fact relevant to that factor is not clearly erroneous, [the appellate court] may reverse if the court evinces a misunderstanding of the legal significance of that historical fact and if that misunderstanding infects the court's ultimate finding.” Shakur, 817 F.2d at 197. MEMORANDUM OF LAW I. Ghislaine Maxwell should be released under §3142(i) because she cannot effectively prepare her defense under the horrific conditions she is facing. Trying to defend against exceedingly old, anonymous allegations is hard enough. Doing so while in de facto solitary confinement without 13 DOJ-OGR-00000925