DOJ-OGR-00000963.jpg
710 KB
Extraction Summary
2
People
3
Organizations
2
Locations
1
Events
1
Relationships
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Quotes
Document Information
Type:
Legal document
File Size:
710 KB
Summary
This legal document argues for Ms. Maxwell's bail, asserting that the government's position on her danger to the community is inconsistent with its stance on Epstein. It highlights the COVID-19 pandemic as a health risk and an impediment to her defense, and contends that Ms. Maxwell is not a flight risk due to her strong community ties, U.S. citizenship, lack of criminal record, and continued presence in the U.S. since Epstein's arrest.
People (2)
| Name | Role | Context |
|---|---|---|
| Epstein | Defendant (implied) |
bail position it took with Epstein; supposed ties to Epstein; Epstein's arrest
|
| Ms. Maxwell | Defendant |
Ms. Maxwell presents a danger; grant bail to Ms. Maxwell; her health will be at serious risk; she is a U.S. citizen; ...
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| government | government agency |
the government does not and cannot assert; presumption relied on by the government; contact with the government
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| Court | government agency |
The Court should exercise its discretion; as modified by the Court; this Court has noted; the Court should grant bail
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| non-profit company | company |
she ran a non-profit company based in the United States
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Locations (2)
| Location | Context |
|---|---|
|
family members and friends in New York
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|
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lived in this country for almost 30 years; non-profit company based in the United States; remained in the United States
|
Relationships (1)
supposed ties to Epstein; contesting civil litigation arising from her supposed ties to Epstein
Full Extracted Text
Complete text extracted from the document (2,069 characters)
Case 1:20-cr-00330-AJN Document 18 Filed 07/16/20 Page 72 of 200
detention. Importantly, in contrast with the bail position it took with Epstein, the government
does not and cannot assert that Ms. Maxwell presents a danger to the community under Section
3142(g)(4).
does not and cannot assert that Ms. Maxwell presents a danger to the community under Section
3142(g)(4).
Ms. Maxwell’s Response. The Court should exercise its discretion to grant bail to Ms.
Maxwell, on the strict conditions proposed below (or as modified by the Court), for two
compelling reasons.
Maxwell, on the strict conditions proposed below (or as modified by the Court), for two
compelling reasons.
First, the COVID-19 crisis and its impact on detained defendants warrants release. As
this Court has noted, the COVID-19 pandemic represents an unprecedented health risk to
incarcerated individuals, and COVID-19-related restrictions on attorney communications with
pretrial detainees significantly impair a defendant’s ability to prepare her defense. Simply put,
under these circumstances, if Ms. Maxwell continues to be detained, her health will be at serious
risk and she will not be able to receive a fair trial. (See infra Section I, pages 5 to 9).
this Court has noted, the COVID-19 pandemic represents an unprecedented health risk to
incarcerated individuals, and COVID-19-related restrictions on attorney communications with
pretrial detainees significantly impair a defendant’s ability to prepare her defense. Simply put,
under these circumstances, if Ms. Maxwell continues to be detained, her health will be at serious
risk and she will not be able to receive a fair trial. (See infra Section I, pages 5 to 9).
Second, the Court should grant bail because the government has not met its burden under
the Bail Reform Act and controlling case law. The presumption relied on by the government
may be rebutted, and is so here. Ms. Maxwell has strong ties to the community: she is a U.S.
citizen and has lived in this country for almost 30 years; she ran a non-profit company based in
the United States until the recent media frenzy about this case forced her to wind it down to
protect her professional colleagues and their organizations; and she has very close ties with
family members and friends in New York and the rest of the country. Nor does her conduct
indicate that she is a flight risk: she has no prior criminal record; has spent years contesting civil
litigation arising from her supposed ties to Epstein; and has remained in the United States from
the time of Epstein’s arrest until the present, with her counsel in regular contact with the
government. She did not flee, but rather left the public eye, for the entirely understandable
the Bail Reform Act and controlling case law. The presumption relied on by the government
may be rebutted, and is so here. Ms. Maxwell has strong ties to the community: she is a U.S.
citizen and has lived in this country for almost 30 years; she ran a non-profit company based in
the United States until the recent media frenzy about this case forced her to wind it down to
protect her professional colleagues and their organizations; and she has very close ties with
family members and friends in New York and the rest of the country. Nor does her conduct
indicate that she is a flight risk: she has no prior criminal record; has spent years contesting civil
litigation arising from her supposed ties to Epstein; and has remained in the United States from
the time of Epstein’s arrest until the present, with her counsel in regular contact with the
government. She did not flee, but rather left the public eye, for the entirely understandable
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DOJ-OGR-00000963
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