📧 Communication

This document is a Reply Memorandum filed by Ghislaine Maxwell's defense team on December 18, 2020, in support of her renewed motion for bail. The defense argues that the government lacks significant documentary evidence, relies solely on witness testimony from decades ago, and that Maxwell has strong ties to the U.S. through her spouse (whose name is redacted) and friends who have pledged assets. The document also addresses flight risk concerns, arguing that extradition from France or the UK is possible or unlikely to be needed due to waivers, and cites a COVID-19 surge at the detention center as further justification for release.