court filing: 20-cr00330-AJN Document 2661 Filed 02/23/21 Page 36 of 9

The document is a court filing arguing for Ghislaine Maxwell's release on bail under certain conditions. It highlights new pretrial motions that challenge the government's case and asserts that Maxwell is not a flight risk. The filing argues that with the proposed bail conditions, Maxwell should be granted bail to prepare for trial.