court filing: 20-cr-330 (AJN) Document 1032

The document argues that Ms. Maxwell should be granted bail due to the unlikelihood of her fleeing and the risks posed by COVID-19 at the Metropolitan Detention Center (MDC), where she is being held. It counters the government's argument that she could flee to another country and highlights the risk of COVID-19 transmission and potential disruption to her legal representation. The filing requests the court to order her release on bail under strict conditions.