In her memorandum opposing the government's motion for detention, Ghislaine Maxwell argues for her pretrial release, emphasizing her lack of criminal history, strong family ties, and significant connections within the United States. She asserts that she has been a U.S. citizen since 2002, has resided in the country for nearly 30 years, and maintains close relationships with her siblings and their children who are U.S. citizens. Maxwell contends that her absence from the public eye following Jeffrey Epstein's arrest was not an attempt to evade law enforcement but a measure to protect herself and her loved ones from intense media scrutiny and threats.
Maxwell further highlights the health risks posed by the COVID-19 pandemic within detention facilities, arguing that these conditions would impede her ability to prepare an adequate defense. She proposes a bail package that includes a $5 million bond, co-signed by six financially responsible individuals, and secured by property in the United Kingdom valued at over $3.75 million. Additionally, she offers to surrender all travel documents and submit to home confinement with electronic monitoring to mitigate any perceived risk of flight.
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Maxwell Bail Document - July 10, 2020 | PDF | Bail | Burden Of Proof (Law) (scribd.com)