💰 Financial Record

This document is a legal memorandum submitted on February 23, 2021, supporting Ghislaine Maxwell's third motion for release on bail in the SDNY. Maxwell proposes two new conditions to assure her appearance: formally renouncing her French and British citizenships to prevent flight to those countries, and placing all assets (except legal fees and living expenses) into a new account monitored by retired Judge William S. Duffey, Jr. The defense argues these unprecedented conditions, combined with her strong ties to the US, negate flight risk and claims she is being unfairly treated as a substitute for Jeffrey Epstein.