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F. The Proposed Bail Package Is Expansive and Far Exceeds What Is Necessary to Reasonably Assure Ms. Maxwell's Presence in Court
In light of the additional information that Ms. Maxwell has provided in connection with this submission, which responds to each of the concerns raised by the government at the initial bail hearing, the government cannot meet its burden to establish that no set of bail conditions would reasonably assure Ms. Maxwell's appearance in court. The proposed bail package is exceptional in its scope, addresses all of the factors that the Court considered in evaluating risk of flight, and is more than sufficient to warrant her release from BOP custody and transfer to restricted home detention.
Courts in this Circuit have ordered release of high-profile defendants with financial means and foreign citizenship on bonds in lower amounts with less or no security with similar or less restrictive conditions:
| DEFENDANT | BOND | SECURED | HOME DETENTION | ELECTRONIC MONITORING | PRIVATE SECURITY | U.S. CITIZEN | FOREIGN CITIZENSHIP |
| --- | --- | --- | --- | --- | --- | --- | --- |
| SADR | $32.6M aggregate | | Nightly Curfew | | NO | NO | Iran | St Kitts-Nevis |
| DREIER | $10M | NO | | | | | NO |
| MADOFF | $10M | | | | NO | | NO |
| KHASHOGGI Extradited from Switzerland | $10M | | | | NO | | Saudi Arabia |
| ESPOSITO | $9.8M | | | Video Only | NO | | NO |
| SABHNANI Wife | $2.5M | | | | NO | | Indonesia |
| SABHNANI Husband | $2M | | | | NO | | India |
| BODMER Arrested -South Korea | $2M | | | | NO | NO | Switzerland |
| KARNI No U.S. Ties | $7.5M | | | | NO | NO | Israel | South Africa |
| HANSON | NOT REPORTED | | | | NO | | China |
| HANSEN Travel to Denmark Permitted | $500K | NO | NO | NO | NO | NO | Denmark |
| MAXWELL | $28.5M aggregate | | | | | | UK | France |
The Court should also not give any weight to the government's speculative assertions that others might provide money and other support to Ms. Maxwell if she were to flee. (Dkt. 22 at