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Case 1:20-cr-00330-AJN Document 103 Filed 12/23/20 Page 5 of 15

PRELIMINARY STATEMENT

The only issue before the Court is whether conditions exist that can reasonably assure
Ms. Maxwell’s appearance during this case. On this renewed application, Ms. Maxwell has put
before the Court a significant bail package, supported by detailed submissions, which warrant
her release on strict conditions. She and her spouse have committed to signing a bond in the full
amount of their net worth, regardless of the ownership of the underlying assets. She has
proffered seven additional sureties, consisting of her family and close friends, many of whom are
U.S. citizens and long-time residents, who have come forward at great personal risk and have
pledged meaningful assets. The government does not challenge the good faith and bona fides of
these proposed sureties. She has provided a detailed report from a respected accounting firm,
which was further reviewed by a former IRS special agent, setting forth a statement of her
financial condition, supported by voluminous documentation. The government does not
challenge the report’s findings, nor its underlying documentation. She has agreed, in writing, to
give up any right she has or could have to contest extradition and submit to all other standard
travel restrictions. And she has noted that a key representation made by the government at the
initial bail hearing as to the strength of its evidence is simply not accurate – █
█ and there is no “significant contemporaneous documentary
evidence” that corroborates its case.

With regard to any other defendant, this record would readily support release on strict
bail conditions, perhaps even on consent. But this is Ghislaine Maxwell, the apparent substitute
for Jeffrey Epstein. So, instead, in its response the government urges the Court to disregard the
significant additional evidence proffered to the Court and further argues that a defendant cannot
be eligible for bail (apparently on any conditions), unless she can provide an absolute guarantee
against all risks. But this is not the legal standard. United States v. Orta, 760 F.2d 887, 888 n.4,

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