This document is page 20 of a legal filing (Document 148) from February 4, 2021, in the case of United States v. Ghislaine Maxwell. It outlines a legal argument based on the 'Turkish factors' to justify the defense's request for early disclosure of the government's witness list. The defense argues that Maxwell has no criminal history, is not a danger to the community, and that the complexity of the case combined with the global pandemic necessitates this disclosure for fair preparation.
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