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B. Houtz

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This document is a page from a defense filing (Reply Memorandum) dated December 28, 2020, arguing for Ghislaine Maxwell's release on bail. The defense counters flight risk arguments by noting Maxwell has not lived in the UK or France for 30 years and cites the recent arrest of associate Jean-Luc Brunel in France as a deterrent to fleeing there. Additionally, the filing argues that a COVID-19 surge at the MDC and potential suspension of legal communications threaten Maxwell's health and constitutional rights.

Legal filing (defense reply memorandum in support of bail)
2025-11-20
Analysis Source

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This legal document is a filing on behalf of Ms. Maxwell requesting release on bail. It argues against the government's assertion that she is a flight risk, citing her proposed bail package and extradition waivers, and claims the government's standard is impossibly high. The filing also uses the recent surge of COVID-19 cases at the MDC and the suspension of her legal visits as further justification for her release, arguing her constitutional rights are being eroded.

Legal document
2025-11-20
Analysis Source

DOJ-OGR-00020117.jpg

This document is page 14 of a defense motion filed on December 23, 2020, arguing for Ghislaine Maxwell's release on bail. The defense argues that flight risk concerns regarding the UK and France are overstated and that the recent arrest of associate Jean-Luc Brunel in France diminishes her incentive to flee there. Additionally, the motion highlights a COVID-19 surge at the MDC (113 cases) and restrictive prison conditions, including mouth inspections and potential suspension of legal calls, as further justification for bail.

Court filing (defense motion/reply regarding bail)
2025-11-20
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