This document is page 35 of a legal filing (Document 102) dated December 14, 2020, arguing for Ghislaine Maxwell's release on bail. The defense argues she is not a flight risk and that her current detention at the MDC constitutes 'de facto solitary confinement' under conditions more severe than USP Florence ADMAX, hindering her ability to prepare her defense. It claims prison wardens have noted the unprecedented nature of her restrictive regime.
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