EFTA00019291.pdf
794 KB
Extraction Summary
13
People
7
Organizations
5
Locations
2
Events
3
Relationships
5
Quotes
Document Information
Type:
Legal memorandum (reply memorandum in support of renewed motion for bail)
File Size:
794 KB
Summary
This document is a Reply Memorandum filed by Ghislaine Maxwell's defense team on December 18, 2020, in support of her renewed motion for bail. The defense argues that the government lacks significant documentary evidence, relies solely on witness testimony from decades ago, and that Maxwell has strong ties to the U.S. through her spouse (whose name is redacted) and friends who have pledged assets. The document also addresses flight risk concerns, arguing that extradition from France or the UK is possible or unlikely to be needed due to waivers, and cites a COVID-19 surge at the detention center as further justification for release.
People (13)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Seeking release on bail, proposing strict conditions including financial bond and waiver of extradition rights.
|
| Jeffrey Epstein | Deceased financier / Co-conspirator |
Mentioned as the primary target of the government's evidence; Maxwell is described as his 'apparent substitute'.
|
| Mark S. Cohen | Attorney |
Defense counsel for Ghislaine Maxwell, Cohen & Gresser LLP.
|
| Christian R. Everdell | Attorney |
Defense counsel for Ghislaine Maxwell, Cohen & Gresser LLP.
|
| Jeffrey S. Pagliuca | Attorney |
Defense counsel for Ghislaine Maxwell, Haddon, Morgan & Foreman P.C.
|
| Laura A. Menninger | Attorney |
Defense counsel for Ghislaine Maxwell, Haddon, Morgan & Foreman P.C.
|
| Bobbi C. Sternheim | Attorney |
Defense counsel for Ghislaine Maxwell, Law Offices of Bobbi C. Sternheim.
|
| Minor Victim-1 | Witness/Accuser |
Only witness whose testimony supports the substantive counts (Counts Two and Four).
|
| William Julié | Legal Expert (France) |
Provided expert report on French extradition law.
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| David Perry | Legal Expert (UK) |
Provided expert report on UK extradition law.
|
| Jean-Luc Brunel | Associate of Epstein |
Mentioned in footnote as recently arrested in France, diminishing Maxwell's incentive to flee there.
|
| Deputy Captain B. Houtz | Prison Official |
Issued memo at MDC regarding legal calls/visits during COVID surge.
|
| [Redacted] | Spouse |
Ghislaine Maxwell's husband, who has offered to co-sign the bond and pledged assets. Name is redacted throughout.
|
Organizations (7)
| Name | Type | Context |
|---|---|---|
| United States District Court Southern District of New York |
Court where the case is being heard.
|
|
| Cohen & Gresser LLP |
Defense law firm.
|
|
| Haddon, Morgan & Foreman P.C. |
Defense law firm.
|
|
| Law Offices of Bobbi C. Sternheim |
Defense law firm.
|
|
| Metropolitan Detention Center (MDC) |
Jail where Maxwell is detained; noted for COVID surge.
|
|
| French Ministry of Justice (MOJ) |
Provided letter regarding extradition of French nationals.
|
|
| Pretrial Services |
Agency that interviewed Maxwell regarding her assets.
|
Timeline (2 events)
2020-12-18
Filing of Reply Memorandum in Support of Renewed Motion for Bail
SDNY Court
Defense Attorneys
Ghislaine Maxwell
Locations (5)
| Location | Context |
|---|---|
|
Location of the court and attorneys' offices.
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|
|
Location of one of the defense law firms.
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|
|
Country of citizenship for Maxwell; discussed in context of extradition.
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Country of citizenship for Maxwell; discussed in context of extradition.
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Location of a property owned by Maxwell.
|
Relationships (3)
Document refers to Maxwell as the 'apparent substitute for Jeffrey Epstein' in the prosecution's eyes.
Document mentions her spouse has come forward as co-signor and describes a committed relationship of over four years.
Footnote mentions his arrest in France for alleged sexual assaults by Jeffrey Epstein, implying a connection.
Key Quotes (5)
"The government now expressly retreats from this position. It is abundantly clear from the government's response that it has no 'significant contemporaneous documentary evidence'..."Source
EFTA00019291.pdf
Quote #1
"But this is Ghislaine Maxwell, the apparent substitute for Jeffrey Epstein."Source
EFTA00019291.pdf
Quote #2
"She and her spouse have committed to signing a bond in the full amount of their net worth, regardless of the ownership of the underlying assets."Source
EFTA00019291.pdf
Quote #3
"Any incentive Ms. Maxwell might have to flee to France has been greatly diminished by the recent arrest in France of Jean-Luc Brunel..."Source
EFTA00019291.pdf
Quote #4
"The government's case against Ms. Maxwell therefore rests entirely on the credibility and reliability of these three witnesses."Source
EFTA00019291.pdf
Quote #5
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