📧 Communication

This document is a legal memorandum filed on December 14, 2020, arguing for Ghislaine Maxwell's release on bail (Case 1:20-cr-00330-AJN). It asserts that Maxwell has deep ties to the U.S., specifically through her spouse (whose name is redacted), and is supported by letters from family and friends willing to post significant financial assets as sureties. The defense argues these letters counter the 'cruel caricature' of Maxwell in the press and address the Court's previous concerns regarding her lack of dependents or ties to the country.