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Case 1:20-cr-00330-AJN Document 100-2 Filed 12/18/20 Page 7 of 36

from us, we would respectfully request that the court leave the proceeding open for a week so that
we can try to satisfy the court because we want to.”)).

The Court declined the defense’s request and instead concluded that the defendant posed a
serious flight risk and that no combination of conditions could ensure her appearance. First, the
Court found that “the nature and circumstances of the offense here weigh in favor of detention,”
given the statutory presumption of detention triggered by charges involving minor victims and the
potential penalties those charges carry. (Tr. 82). Second, the Court determined that “[t]he
government’s evidence at this early juncture of the case appears strong” based on the “multiple
victims who provided detailed accounts of Ms. Maxwell’s involvement in serious crimes,” as well
as corroboration in the form of “significant contemporaneous documentary evidence.” (Id.).
Third, the Court found that the defendant’s history and characteristics demonstrate that the
defendant poses a risk of flight. (Tr. 83).

In addressing that third factor, the Court emphasized the defendant’s “substantial
international ties,” which “could facilitate living abroad,” including “multiple foreign
citizenships,” “familial and personal connections abroad,” and “at least one foreign property of
significant value.” (Tr. 83). The Court also noted that the defendant “is a citizen of France, a
nation that does not appear to extradite its citizens.” (Id.). The Court further found that the
defendant “possesses extraordinary financial resources” and that “the representations made to
Pretrial Services regarding the defendant’s finances likely do not provide a complete and candid
picture of the resources available.” (Tr. 83-84).

Although the Court recognized that the defendant “does have some family and personal
connections to the United States,” the Court highlighted “the absence of any dependents,
significant family ties or employment in the United States” in support of the conclusion that “flight

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