DOJ-OGR-00001328.pdf

Case 21-770, Document 40-1, 04/12/2021, 3075763, Page11 of 25 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 highlighted that in July 2020 Maxwell represented to Pretrial Services that she possessed around $3.5 million in assets, but in connection with her renewed request for bail presented a report on her finances that estimated the net worth of Maxwell and her spouse to be approximately $22.5 million as of October 2020. (Id. at 15). Judge Nathan found that the difference "makes it unlikely that the misrepresentation was the result of the Defendant's misestimation rather than misdirection." (Id. at 15-16). She explained: In sum, the evidence of a lack of candor is, if anything, stronger now than in July 2020, as it is clear to the Court that the Defendant's representations to Pretrial Services were woefully incomplete. That lack of candor raises significant concerns as to whether the Court has now been provided a full and accurate picture of her finances and as to the Defendant's willingness to abide by any set of conditions of release. (Id. at 16). 21. Judge Nathan again concluded that Maxwell presented a risk of flight and that Maxwell's proposed bail package "cannot reasonably assure her appearance," as it "would leave unrestrained millions of dollars and other assets that she could sell in order to support herself" and the "proposed bond is only partially secured." (Id. at 16-18). Judge Nathan explained that the pledge of several third 11 DOJ-OGR-00001328