DOJ-OGR-00019855.pdf

Case 21-58, Document 39-1, 04/01/2021, 3068530, Page27 of 31 constantly monitored. And of course, she is recognizable around the globe. The truth is that wealthy men charged with similar or more serious offenses, many of whom have foreign ties, are routinely granted bail so that they can effectively prepare for trial. Bernie Madoff. Harvey Weinstein. Bill Cosby. John Gotti. Marc Dreier. Dominique Strauss-Kahn. Ali Sadr. Adnan Khashoggi. Mahender Sabhnani. The list goes on and on. In each case, the court set reasonable conditions of bond and the defendants appeared, despite similar arguments by the government that the defendant faced serious charges or that the evidence was strong or that he had foreign ties or that he had great wealth. Ms. Maxwell is entitled to the same opportunity as male defendants to prepare her defense. Even putting aside the pandemic and the current conditions of Ms. Maxwell's confinement, pretrial detention "is an extraordinary remedy" that should be reserved for only a very "limited group of offenders." United States v. Jackson, 823 F.2d 4, 8 (2d Cir. 1987). For this reason, a judge may deny a defendant bail "only for the strongest of reasons." Hung v. United States, 439 U.S. 1326, 1329 (1978) (Brennan, 25 DOJ-OGR-00019855