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641 KB

Extraction Summary

4
People
1
Organizations
1
Locations
2
Events
1
Relationships
2
Quotes

Document Information

Type: Legal document
File Size: 641 KB
Summary

This legal document is part of a defense argument for Ms. Maxwell's bail application. The defense counters the government's assertion that she is a flight risk by highlighting a proposed 'substantial bail package' backed by her, her spouse, and co-signers, which would create severe financial consequences for them if she were to flee. The document also refutes the government's characterization of Ms. Maxwell as an expert at hiding and clarifies financial details regarding her spouse's assets.

People (4)

Name Role Context
Ms. Maxwell Defendant
The central subject of the document, whose bail package and flight risk are being discussed.
Ms. Maxwell's spouse Spouse of Defendant
Mentioned as having liquidated investments to help Ms. Maxwell and having pledged all assets in support of her bond.
co-signers Supporters of bail package
Mentioned as part of the proposed substantial bail package.
friends and family Supporters of Defendant
Mentioned as facing significant financial consequences if Ms. Maxwell leaves the country.

Organizations (1)

Name Type Context
The Government Government agency
The opposing party in the legal case, asserting that Ms. Maxwell is a flight risk.

Timeline (2 events)

Proposal of a substantial bail package for Ms. Maxwell, supported by her spouse and co-signers.
The government asserts that Ms. Maxwell is a flight risk and has an expertise at hiding.

Locations (1)

Location Context
Mentioned in the context of Ms. Maxwell potentially leaving it, which would trigger financial consequences.

Relationships (1)

Ms. Maxwell Marital and financial Ms. Maxwell's spouse
The document states they have pledged all their joint assets for her bond, that he liquidated investments to help her, and that he would be 'left with nothing' if she flees. It also mentions that Ms. Maxwell brought the majority of assets to the relationship.

Key Quotes (2)

"Adept"
Source
— The Government (as characterized by the defense) (Used in the section heading to describe the government's assertion that Ms. Maxwell is adept at hiding.)
DOJ-OGR-00002217(1).jpg
Quote #1
"an expertise at remaining hidden"
Source
— The Government (as characterized by the defense) (Part of the 'sinister narrative' the government is said to be asserting about Ms. Maxwell.)
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Quote #2

Full Extracted Text

Complete text extracted from the document (1,989 characters)

Case 1:20-cr-00330-AJN Document 103 Filed 12/23/20 Page 11 of 15
[REDACTED]
[REDACTED]
[REDACTED] Similarly, the financial report does not include
a future income stream for Ms. Maxwell or her spouse because it presents only historical
and current assets. Even so, Ms. Maxwell has no certain future income stream. Her spouse
[REDACTED] and has had to liquidate his existing investments to help Ms. Maxwell. Finally, the
reference to [REDACTED] is gratuitous. Ms. Maxwell had no knowledge of [REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
But the larger point is this: Ms. Maxwell has proposed a substantial bail package
with multiple co-signers and significant security. She and her spouse have pledged all of
their assets in support of the bond. Ms. Maxwell’s wealth is not a reason to deny her bail. It
is a reason to set appropriately strict conditions that will result in significant financial
consequences to Ms. Maxwell and her friends and family if she leaves the country. The
proposed bail package does exactly that.⁶
C. The Government’s Assertion that Ms. Maxwell Is “Adept” at Hiding and
Therefore a Flight Risk Is Specious
The government continues to assert the sinister narrative that Ms. Maxwell had “an
expertise at remaining hidden,” and that it would therefore be easy for her to become a fugitive.
⁶ The government’s argument that her spouse’s moral suasion is diminished because Ms. Maxwell brought the
majority of assets to the relationship is nonsensical. (Id. at 24-25). Regardless of whose money it was to begin with,
all of the assets of Ms. Maxwell and her spouse will be forfeited if she flees and her spouse [REDACTED] will be
left with nothing. Furthermore, the government’s assertion that they could not verify the spouse’s financial
information because Ms. Maxwell did not provide his current banking information is false. (Id. at 24 n.9). The
defense provided the spouse’s current banking records and only redacted the name of the bank.
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