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Case#: 20-cr00880 Document#: 11032 Filed: 06/23/20 Page#: 5 of 515
mistaken. Prior to her arrest, Ms. Maxwell and her spouse had discussed the idea of getting
a divorce as an additional way to create distance between Ms. Maxwell and her spouse to
protect him from the terrible consequences of being associated with her.
Nevertheless, in the weeks following the initial bail hearing,
She and her spouse therefore had no reason to continue
discussing divorce, which neither of them wanted in the first place. Nor was there any
reason for her spouse to refrain from stepping forward as a co-signer. In sum, the
government has offered nothing but unsupported innuendo to suggest that Ms. Maxwell's
relationship with her spouse is not a powerful tie to this country.
The government's assertion that Ms. Maxwell must not have a close relationship
with is particularly callous
and belied by the facts. (Gov. Mem. at 14). As her spouse explains,
(Ex. A ¶ 12).
B. Ms. Maxwell Has Thoroughly Disclosed Her Finances and Pledged All of
Her and Her Spouse's Assets in Support of Her Bond
The government's attempts to rebut the financial condition report are unavailing.
Significantly, the government does not contest the accuracy of the report, nor the
voluminous supporting documentation. In fact, the government has proffered nothing that
calls into question the report's detailed account of Ms. Maxwell and her spouse's assets for
the last five years, which addresses one of the Court's principal reasons for denying bail.
Rather than question the report itself, the government attempts to argue that Ms.
Maxwell deceived the Court and Pretrial Services about her assets. (Gov. Mem. at 22-23).
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DOJ-OGR-00001194