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Hon. Margo K. Brodie

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person Sean Hecker
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DOJ-OGR-00001593.jpg

This page is from a legal memorandum filed on July 10, 2020, arguing for the pretrial release of Ghislaine Maxwell. The defense contends that the government has failed to prove she is a flight risk or that no conditions exist to assure her appearance, citing the Bail Reform Act and Supreme Court precedent (Salerno) establishing liberty as the norm and detention as an exception. A footnote references a separate letter regarding poor prison conditions, including lack of visitation and legal access, which the defense argues are 'compelling reasons' for release.

Court filing (legal memorandum/motion for bail)
2025-11-20
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Prison Conditions

From: Sean Hecker
To: Hon. Margo K. Brodie

Details absence of in-person visitation, limited VTC/telephone capacity, and issues with legal mail.

Letter
2020-07-08
Communication Source

Prison conditions / Legal access

From: Sean Hecker
To: Hon. Margo K. Brodie

Details absence of in-person visitation, limited VTC/phone capacity, and issues with legal mail.

Letter
2020-07-08
Communication Source

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