423 [DOJ-OGR-00006201—DOJ-OGR-00006211]

_ Case 1:20-cr-00330-PAE Document 423 Filed 11/08/21 Page 1of11 pee U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew’s Plaza New York, New York 10007 November 8, 2021 BY ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in opposition to the defendant’s motion to reconsider this Court’s prior bail determinations. (Dkt. 408 (“Def. Mot.’”)). This Court has repeatedly found that there are no conditions of release that can reasonably assure the defendant’s appearance (Dkt. 93, 106, 169), and the Second Circuit has twice rejected the defendant’s appeals (see United States v. Maxwell, No. 21-58, Dkt. 86, 96 (2d Cir.)). The defendant’s latest motion largely repeats arguments that have been made and rejected before. There is no basis for the Court to reconsider its prior rulings. A. Procedural History 1. The Court’s First Detention Order After the defendant’s arrest, this Court received multiple written submissions and held a lengthy oral argument on the question of bail. (See Dkt. 93 (“First Order’”)). On July 14, 2020, in a detailed oral ruling, the Court ordered the defendant detained on the basis of risk of flight. (/d. at 79-91). 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 DOJ-OGR-00006201