DOJ-OGR-00002012.jpg
663 KB
Extraction Summary
12
People
3
Organizations
13
Locations
2
Events
1
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
663 KB
Summary
This legal document, filed on December 14, 2020, argues for the approval of a proposed $28.5 million bail package for defendant Ms. Maxwell. It contends that this package is more than sufficient to ensure her appearance in court by comparing it to the less restrictive bail conditions of other high-profile defendants with significant financial means and foreign citizenships. A table is provided to illustrate these precedents, detailing bond amounts and conditions for defendants such as Madoff, Khashoggi, and others.
People (12)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
The subject of the proposed bail package, referred to throughout the document.
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| SADR | Defendant |
Listed in a table of defendants with details of their bail conditions.
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| DREIER | Defendant |
Listed in a table of defendants with details of their bail conditions.
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| MADOFF | Defendant |
Listed in a table of defendants with details of their bail conditions.
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| KHASHOGGI | Defendant |
Listed in a table of defendants with details of their bail conditions. Noted as 'Extradited from Switzerland'.
|
| ESPOSITO | Defendant |
Listed in a table of defendants with details of their bail conditions.
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| SABHNANI (Wife) | Defendant |
Listed in a table of defendants with details of their bail conditions.
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| SABHNANI (Husband) | Defendant |
Listed in a table of defendants with details of their bail conditions.
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| BODMER | Defendant |
Listed in a table of defendants with details of their bail conditions. Noted as 'Arrested -South Korea'.
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| KARNI | Defendant |
Listed in a table of defendants with details of their bail conditions. Noted as 'No U.S. Ties'.
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| HANSON | Defendant |
Listed in a table of defendants with details of their bail conditions.
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| HANSEN | Defendant |
Listed in a table of defendants with details of their bail conditions. Noted as 'Travel to Denmark Permitted'.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| BOP | government agency |
Mentioned as the agency from whose custody Ms. Maxwell's release is sought ('release from BOP custody').
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| Court | government agency |
Referenced throughout as the judicial body being addressed and the one that considers bail factors.
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| government | government agency |
The opposing party in the legal proceeding, whose concerns about bail are being addressed.
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Timeline (2 events)
2020-12-14
Document 97 was filed in Case 1:20-cr-00330-AJN, arguing for Ms. Maxwell's release on a proposed bail package.
Ms. Maxwell's legal team
An initial bail hearing was held where the government raised concerns about Ms. Maxwell's bail.
Court
Locations (13)
| Location | Context |
|---|---|
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Listed as a foreign citizenship for defendant SADR.
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Listed as a foreign citizenship for defendant SADR.
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Listed as the country from which defendant KHASHOGGI was extradited and as a foreign citizenship for defendant BODMER.
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Listed as a foreign citizenship for defendant KHASHOGGI.
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Listed as a foreign citizenship for defendant SABHNANI (Wife).
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Listed as a foreign citizenship for defendant SABHNANI (Husband).
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Listed as the location of arrest for defendant BODMER.
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Listed as a foreign citizenship for defendant KARNI.
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Listed as a foreign citizenship for defendant KARNI.
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Listed as a foreign citizenship for defendant HANSON.
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Listed as a permitted travel destination and foreign citizenship for defendant HANSEN.
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Listed as a foreign citizenship for defendant MAXWELL.
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Listed as a foreign citizenship for defendant MAXWELL.
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Relationships (1)
The document lists them separately in a table, explicitly labeling them 'Wife' and 'Husband'.
Full Extracted Text
Complete text extracted from the document (2,146 characters)
Case 1:20-cr-00330-AJN Document 97 Filed 12/14/20 Page 40 of 45
F. The Proposed Bail Package Is Expansive and Far Exceeds What Is Necessary to Reasonably Assure Ms. Maxwell’s Presence in Court
In light of the additional information that Ms. Maxwell has provided in connection with this submission, which responds to each of the concerns raised by the government at the initial bail hearing, the government cannot meet its burden to establish that no set of bail conditions would reasonably assure Ms. Maxwell’s appearance in court. The proposed bail package is exceptional in its scope, addresses all of the factors that the Court considered in evaluating risk of flight, and is more than sufficient to warrant her release from BOP custody and transfer to restricted home detention.
Courts in this Circuit have ordered release of high-profile defendants with financial means and foreign citizenship on bonds in lower amounts with less or no security with similar or less restrictive conditions:
DEFENDANT | BOND | SECURED | HOME DETENTION | ELECTRONIC MONITORING | PRIVATE SECURITY | U.S. CITIZEN | FOREIGN CITIZENSHIP
SADR | $32.6M aggregate | YES | Nightly Curfew | YES | NO | NO | Iran | St Kitts-Nevis
DREIER | $10M | NO | YES | YES | YES | YES | NO
MADOFF | $10M | YES | YES | YES | NO | YES | NO
KHASHOGGI Extradited from Switzerland | $10M | YES | YES | YES | NO | YES | Saudi Arabia
ESPOSITO | $9.8M | YES | YES | YES | Video Only | YES | NO
SABHNANI Wife | $2.5M | YES | YES | YES | NO | YES | Indonesia
SABHNANI Husband | $2M | YES | YES | YES | NO | YES | India
BODMER Arrested -South Korea | $2M | YES | YES | YES | NO | NO | Switzerland
KARNI No U.S. Ties | $7.5M | YES | YES | YES | NO | NO | Israel | South Africa
HANSON | NOT REPORTED | YES | YES | YES | NO | YES | China
HANSEN Travel to Denmark Permitted | $500K | NO | NO | NO | NO | NO | Denmark
MAXWELL | $28.5M aggregate | YES | YES | YES | YES | YES | UK | France
SADR | $32.6M aggregate | YES | Nightly Curfew | YES | NO | NO | Iran | St Kitts-Nevis
DREIER | $10M | NO | YES | YES | YES | YES | NO
MADOFF | $10M | YES | YES | YES | NO | YES | NO
KHASHOGGI Extradited from Switzerland | $10M | YES | YES | YES | NO | YES | Saudi Arabia
ESPOSITO | $9.8M | YES | YES | YES | Video Only | YES | NO
SABHNANI Wife | $2.5M | YES | YES | YES | NO | YES | Indonesia
SABHNANI Husband | $2M | YES | YES | YES | NO | YES | India
BODMER Arrested -South Korea | $2M | YES | YES | YES | NO | NO | Switzerland
KARNI No U.S. Ties | $7.5M | YES | YES | YES | NO | NO | Israel | South Africa
HANSON | NOT REPORTED | YES | YES | YES | NO | YES | China
HANSEN Travel to Denmark Permitted | $500K | NO | NO | NO | NO | NO | Denmark
MAXWELL | $28.5M aggregate | YES | YES | YES | YES | YES | UK | France
The Court should also not give any weight to the government’s speculative assertions that others might provide money and other support to Ms. Maxwell if she were to flee. (Dkt. 22 at
34
DOJ-OGR-00002012
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