DOJ-OGR-00000974.jpg

742 KB

Extraction Summary

5
People
4
Organizations
2
Locations
6
Events
2
Relationships
3
Quotes

Document Information

Type: Legal document
File Size: 742 KB
Summary

This legal document argues that Ms. Maxwell is not a flight risk, citing prior court decisions where defendants who knew of impending charges did not flee. It emphasizes that the government had no evidence of Ms. Maxwell planning to leave the country and arrested her without warning before a holiday. The document further contends that Ms. Maxwell's actions to avoid public scrutiny after Epstein's arrest do not indicate an intent to flee.

People (5)

Name Role Context
Ms. Maxwell Defendant
The government arrested Ms. Maxwell; Ms. Maxwell’s Actions to Protect Herself From Intrusive Media Coverage and Death...
Epstein
one-year anniversary of Epstein’s arrest; after Epstein’s arrest
DiGiacomo Defendant
United States v. DiGiacomo
defendant Defendant
defendant posed a flight risk; defendant took 'no steps' to flee
counsel Legal representative
government alerted her counsel

Organizations (4)

Name Type Context
United States government agency
United States v. DiGiacomo
government government agency
allegation by the government; government has offered no proof; government alerted her counsel; government arrested Ms...
2d Cir. court
837 F.2d 48, 49-50 (2d Cir. 1988)
D. Mass. court
746 F. Supp. 1176, 1179-80 (D. Mass. 1990)

Timeline (6 events)

1988
Overturning district court’s decision that defendant posed a flight risk
2d Cir.
1990
Concluding defendants did not present a flight risk
D. Mass.
defendants
Execution of search warrant at home and arrest
home
Ms. Maxwell's arrest by the government without warning
Epstein's arrest (one-year anniversary mentioned in relation to Ms. Maxwell's custody)
July 4th
July 4th holiday

Locations (2)

Location Context
taking steps to leave the country; plans to leave the country
execution of search warrant at home

Relationships (2)

Ms. Maxwell professional/associative Epstein
Ms. Maxwell took steps to leave the public eye after Epstein’s arrest
Ms. Maxwell professional (client-attorney) counsel
had the government alerted her counsel that she was about to be arrested, we would have arranged for Ms. Maxwell’s prompt, voluntary surrender

Key Quotes (3)

"no steps"
Source
DOJ-OGR-00000974.jpg
Quote #1
"for three years knew there was substantial evidence of the likely charges against them and did not attempt to flee before indictment"
Source
DOJ-OGR-00000974.jpg
Quote #2
"Ms. Maxwell’s Actions to Protect Herself From Intrusive Media Coverage and Death Threats Do Not Demonstrate an Intent to Flee"
Source
DOJ-OGR-00000974.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (2,091 characters)

Case 1:20-cr-00530-AJN Document 184 Filed 07/10/20 Page 18 of 260
837 F.2d 48, 49-50 (2d Cir. 1988) (overturning district court’s decision that defendant posed
a flight risk based in part on the ground that the defendant took “no steps” to flee
jurisdiction in three-week period between execution of search warrant at home and arrest);
United States v. DiGiacomo, 746 F. Supp. 1176, 1179-80 (D. Mass. 1990) (concluding
defendants did not present a flight risk because each of them “for three years knew there
was substantial evidence of the likely charges against them and did not attempt to flee
before indictment”). 837 F.2d 48, 49-50 (2d Cir. 1988) (overturning district court’s decision
that defendant posed a flight risk based in part on the ground that the defendant took “no
steps” to flee jurisdiction in three-week period between execution of search warrant at home
and arrest); United States v. DiGiacomo, 746 F. Supp. 1176, 1179-80 (D. Mass. 1990)
(concluding defendants did not present a flight risk because each of them “for three years
knew there was substantial evidence of the likely charges against them and did not attempt
to flee before indictment”).
f
Indeed, the absence of any allegation by the government that Ms. Maxwell was
taking steps to leave the country at the time of her arrest is conspicuous. The government
has offered no proof that she was making plans to leave the country. In fact, had the
government alerted her counsel that she was about to be arrested, we would have arranged
for Ms. Maxwell’s prompt, voluntary surrender. Instead, the government arrested Ms.
Maxwell without warning on the day before the July 4th holiday, thus ensuring that she
would be in federal custody on the one-year anniversary of Epstein’s arrest.
c. Ms. Maxwell’s Actions to Protect Herself From Intrusive Media
Coverage and Death Threats Do Not Demonstrate an Intent to
Flee
Furthermore, the steps Ms. Maxwell took to leave the public eye after Epstein’s
arrest are not indicative of a risk of flight. The government notes that Ms. Maxwell dropped
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