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Deputy Captain B. Houtz

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EFTA00019291.pdf

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.

Legal memorandum (reply memorandum in support of renewed motion for bail)
2025-12-25
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Continuity of legal calls and visits

From: Deputy Captain B. Houtz
To: Unknown

A memo was recently issued by Deputy Captain B. Houtz stating that it has not been determined whether legal calls and legal visits will continue at the MDC.

Memo
N/A
Communication Source

Legal calls/visits

From: Deputy Captain B. Houtz
To: MDC Staff/Inmates

Stating it has not been determined whether legal calls and legal visits will continue.

Memo
N/A
Communication Source

Legal calls and visits

From: Deputy Captain B. Houtz
To: MDC Staff/Inmates (imp...

Stating it has not been determined whether legal calls and legal visits will continue.

Memo
2020-12-01
Communication Source

Continuation of legal calls/visits

From: Deputy Captain B. Houtz
To: MDC Staff/Inmates (imp...

Stated that '[i]t has not been determined whether legal calls and legal visits will continue.'

Memo
2020-12-01
Communication Source

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