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Case 21-770, Document 20-1, 04/01/2021, 3068530, Page19 of 31 officer who issued an order of detention to, by subsequent order, “permit the temporary release of the person ... to the extent that the judicial officer determines such release to be necessary for preparation of the person’s defense or for another compelling reason.” § 3142(). The presumption of innocence should not be paid mere lip service, the court held, and being held without the ability to see counsel face-to-face was “no way to prepare for trial.” Ms. Maxwell presents a more compelling case than Robertson for temporary release under § 3142(1). Courts considering whether pretrial release is necessary have considered: “(1) [the] time and opportunity the defendant has to prepare for the trial and to participate in his defense; (2) the complexity of the case and volume of information; and (3) expense and inconvenience associated with preparing’ while incarcerated.” Robertson, (citing United States v. Boatwright, 2020 WL 1639855, at *4 (D. Nev. Apr. 2, 2020) (unreported) (citations omitted). Trial is set for July. There is precious little time left to prepare and participate in that preparation. The discovery involves millions of pages of documents. Ms. Maxwell cannot conduct searches of these documents; she cannot print them and spread them out on a desk for review; she cannot make notes on the documents; and she cannot move 17 DOJ-OGR-00000929