📧 Communication

This document is a legal memorandum filed by Ghislaine Maxwell's defense team arguing against the government's motion for detention and requesting release on bail. The defense argues that the COVID-19 pandemic poses a severe health risk and impedes defense preparation, and asserts that Maxwell is not a flight risk, citing her presence in the U.S. since Epstein's arrest. They propose a $5 million bond secured by UK property and strict conditions including home confinement and GPS monitoring.