This document is page 17 of a court filing (Document 22) in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on July 13, 2020. The text argues against granting bail, citing an 'extraordinary risk of flight' and rejecting the defendant's claim that detention at the MDC prevents adequate preparation for defense. The filing cites numerous precedents (Tolentino, Adamu, Brito, etc.) where bail was denied despite access-to-counsel restrictions, distinguishing the current case from *United States v. Stephens*.
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