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746 KB
Extraction Summary
5
People
2
Organizations
4
Locations
3
Events
1
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
746 KB
Summary
This legal document is a filing on behalf of Ms. Maxwell requesting release on bail. It argues against the government's assertion that she is a flight risk, citing her proposed bail package and extradition waivers, and claims the government's standard is impossibly high. The filing also uses the recent surge of COVID-19 cases at the MDC and the suspension of her legal visits as further justification for her release, arguing her constitutional rights are being eroded.
People (5)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
The subject of the bail request, arguing against the government's claim that she is a flight risk and citing COVID co...
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| Chen |
Named in the case citation 'United States v. Chen', used to argue that the Bail Reform Act does not require 'ironclad...
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| B. Houtz | Deputy Captain |
Issued a memo at MDC stating it was undetermined if legal calls and visits would continue.
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| Jean-Luc Brunel | Modeling Agent |
Mentioned in a footnote regarding his recent arrest in France, which is argued to diminish Ms. Maxwell's incentive to...
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| Jeffrey Epstein |
Mentioned in a footnote in the context of an inquiry related to Jean-Luc Brunel's arrest for alleged sexual assaults.
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Organizations (2)
| Name | Type | Context |
|---|---|---|
| MDC | government agency |
Metropolitan Detention Center where Ms. Maxwell is being held, experiencing a COVID surge.
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| The Guardian | company |
Cited via a URL in a footnote as a source for information on Jean-Luc Brunel's arrest.
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Timeline (3 events)
A surge in COVID-19 cases at the MDC, reaching 113 positive cases.
MDC
Locations (4)
| Location | Context |
|---|---|
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Mentioned as a country to which Ms. Maxwell has ties, but where she has not lived for nearly 30 years.
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Mentioned as a country to which Ms. Maxwell has ties and might flee, though this incentive is argued to be diminished...
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Northern District of California, mentioned in the citation for 'United States v. Chen'.
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The detention center where Ms. Maxwell is held and where there is a COVID surge.
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Relationships (1)
The document states that Jean-Luc Brunel, a modeling agent, is under investigation for alleged sexual assaults by Jeffrey Epstein, as part of the 'Jeffrey Epstein Inquiry'.
Key Quotes (2)
"Section 3142 does not seek ironclad guarantees."Source
— United States v. Chen
(Quoted from a legal precedent to argue against the government's high standard for granting bail.)
DOJ-OGR-00002220(1).jpg
Quote #1
"[i]t has not been determined whether legal calls and legal visits will continue."Source
— Deputy Captain B. Houtz
(Quoted from a memo to highlight the uncertainty of Ms. Maxwell's access to counsel, further justifying her release on bail.)
DOJ-OGR-00002220(1).jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (2,378 characters)
Case 1:20-cr-00330-AJN Document 103 Filed 12/23/20 Page 14 of 15
Finally, the government’s argument that Ms. Maxwell could always flee to some country other than the United Kingdom and France holds her—and any defendant—to an impossible standard, which is not the standard under the Bail Reform Act. (See Gov. Mem. at 19). By the government’s reasoning, no defendant with financial means to travel could be granted bail, because there would always be a possibility that they could flee to another country (even if they had no ties there), and there could never be an assurance that any extradition waiver would be enforced. However, “Section 3142 does not seek ironclad guarantees.” United States v. Chen, 820 F. Supp. 1205, 1208 (N.D. Cal. 1992). To the extent that Ms. Maxwell’s ties to France and the United Kingdom—where she has not lived for nearly 30 years—create a flight risk, her extradition waivers along with the substantial bail package proposed reasonably cure it.⁸
E. The Recent COVID Surge at MDC Further Justifies Bail
The government suggests that the Court ignore COVID concerns because Ms. Maxwell, though quarantined because of contact with an officer who tested positive, did not become infected. This ignores the daily (sometimes multiple) inspections of Ms. Maxwell’s mouth, which heightens her risk of contracting the deadly virus, which has now surged to 113 positive cases in the MDC. Further, Deputy Captain B. Houtz recently issued a memo stating that “[i]t has not been determined whether legal calls and legal visits will continue.” As the Court is well aware, legal visits with Ms. Maxwell already have been suspended. Should legal calls also be discontinued, her constitutional right to effective assistance of counsel will be further eroded.
CONCLUSION
For the foregoing reasons, Ms. Maxwell respectfully requests that the Court order her release on bail pursuant to the strict conditions she has proposed.
⁸ Any incentive Ms. Maxwell might have to flee to France has been greatly diminished by the recent arrest in France of Jean-Luc Brunel, who reportedly is under investigation for alleged sexual assaults by Jeffrey Epstein. See, e.g., France Detains Modeling Agent in Jeffrey Epstein Inquiry, https://www.theguardian.com/world/2020/dec/17/france-detains-modelling-agent-jean-luc-brunel-in-jeffrey-epstein-inquiry.
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