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Case 21-770, Document 73, 05/27/2021, 3109708, Page7 of 24

13. Second, on December 8, 2020, Maxwell renewed her request for bail, presenting a revised bail package with additional financial restrictions. (Ex. E). After considering multiple written submissions (Ex. E, F, G), Judge Nathan denied Maxwell’s application in a detailed written opinion (Ex. H). Judge Nathan found that the arguments presented “either were made at the initial bail hearing or could have been made then” and the new information “only solidifies the Court’s view that [Maxwell] plainly poses a risk of flight and that no combination of conditions can ensure her appearance.” (Ex. H at 1-2). Among other things, Judge Nathan concluded that the case against Maxwell “remains strong” in light of the Government’s proffer of evidence. (Id. at 10). Judge Nathan further found that Maxwell still had “substantial international ties,” “multiple foreign citizenships,” “familial and personal connections abroad,” and “extraordinary financial resources” that would still “provide her the means to flee the country and to do so undetected.” (Id. at 11-13). Judge Nathan emphasized that Maxwell’s “pattern of providing incomplete or erroneous information to the Court or to Pretrial Services bears significantly” on her assessment of Maxwell’s history and characteristics. (Id. at 15). Judge Nathan therefore again concluded that Maxwell presented a risk of flight and that Maxwell’s proposed bail package “cannot reasonably assure her appearance.” (Id. at 16). Additionally, Judge Nathan was

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