DOJ-OGR-00020105.jpg

449 KB

Extraction Summary

2
People
3
Organizations
4
Locations
1
Events
1
Relationships
1
Quotes

Document Information

Type: Legal document
File Size: 449 KB
Summary

This document is the table of contents for a legal filing on behalf of Ms. Maxwell, dated December 23, 2020, likely related to a bail application. The arguments outlined challenge the government's case by highlighting its reliance on limited witness testimony, asserting Ms. Maxwell's strong ties to the U.S. (including her spouse), her full financial disclosure for a bond, and the low probability of her being a flight risk. The filing also leverages a recent COVID surge at the MDC facility as an additional reason for granting bail.

People (2)

Name Role Context
Ms. Maxwell Subject of the legal filing
Mentioned throughout the table of contents as the central figure in a legal argument concerning her bail application.
Ms. Maxwell's Spouse Spouse
Mentioned as part of Ms. Maxwell's substantial ties to the United States and in relation to assets pledged for her bo...

Organizations (3)

Name Type Context
The Government Government agency
The opposing party in the legal case, whose arguments and assertions are being countered in this filing.
Court Government agency
The entity being asked by the Government to ignore Ms. Maxwell's ties to the United States.
MDC Government facility
A location experiencing a COVID surge, which is used as an argument to justify bail.

Timeline (1 events)

A recent COVID surge at MDC is cited as a reason to justify bail.
MDC

Locations (4)

Location Context
A country to which Ms. Maxwell is argued to have substantial ties.
Mentioned as a country from which refusal of extradition is considered highly unlikely.
Mentioned as a country from which refusal of extradition is considered highly unlikely.
MDC
The location of a recent COVID surge, cited as a reason for granting bail.

Relationships (1)

The document explicitly mentions 'Her Spouse' in the context of her ties to the United States and their shared assets pledged for her bond.

Key Quotes (1)

"Adept"
Source
— The Government (Used in the Government's assertion that Ms. Maxwell is 'Adept' at Hiding, which is being argued as specious.)
DOJ-OGR-00020105.jpg
Quote #1

Full Extracted Text

Complete text extracted from the document (1,642 characters)

Case 1:20-cr-00330-AJN Document 132 Filed 12/23/20 Page 2 of 15
TABLE OF CONTENTS
Page
PRELIMINARY STATEMENT ......................................................................................................... 1
ARGUMENT .................................................................................................................................... 2
I. The Government Concedes that Its Case Relies Almost Exclusively on the
Testimony of Three Witnesses ............................................................................................ 2
II. The Government Has Not Carried Its Burden..................................................................... 4
A. The Government Asks the Court to Ignore Ms. Maxwell’s Substantial
Ties to the United States, Including Her Spouse [REDACTED] ............................ 4
B. Ms. Maxwell Has Thoroughly Disclosed Her Finances and Pledged All
of Her and Her Spouse’s Assets in Support of Her Bond ..................................... 5
C. The Government’s Assertion that Ms. Maxwell Is “Adept” at Hiding and
Therefore a Flight Risk Is Specious ....................................................................... 7
D. Refusal of Extradition from France or the United Kingdom Is Highly
Unlikely................................................................................................................... 8
E. The Recent COVID Surge at MDC Further Justifies Bail ................................. 10
CONCLUSION............................................................................................................................... 10
i
DOJ-OGR-00020105

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