DOJ-OGR-00001106.jpg
648 KB
Extraction Summary
5
People
3
Organizations
1
Locations
3
Events
2
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
648 KB
Summary
This legal document is part of a court filing by Ms. Maxwell's defense team, presenting new information to support a renewed bail application. The defense provides several pieces of evidence, including a letter from her spouse, character references from friends and family, and a detailed financial report from the firm Macalvins Limited showing assets of approximately $22.5 million. The filing aims to demonstrate Ms. Maxwell's strong ties to the U.S. and counter arguments that she is a flight risk or was hiding from law enforcement.
People (5)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
The subject of a renewed bail application, whose assets, character, and relationships are being presented to the Court.
|
| Ms. Maxwell's spouse | Spouse |
Wrote a letter in support of Ms. Maxwell, is a U.S. citizen, and his assets are included in a financial report. He di...
|
| Jeffrey Epstein |
Mentioned in the context of media frenzy and threats following his arrest and death, which allegedly threatened Ms. M...
|
|
| Unnamed former IRS agent | Former IRS agent |
Reviewed a financial report on Ms. Maxwell's assets and confirmed its accuracy. The name is redacted in the document.
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| The person in charge of Ms. Maxwell’s security | Head of Security |
Provided a statement rebutting the government's claim that Ms. Maxwell attempted to hide from law enforcement.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Court | government agency |
The recipient of the new information for consideration in a renewed bail application.
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| Macalvins Limited | company |
An accounting firm that prepared a financial report on Ms. Maxwell's financial condition from 2015-2020.
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| IRS | government agency |
Mentioned as the former employer of an agent who reviewed Ms. Maxwell's financial report.
|
Timeline (3 events)
Arrest of Ms. Maxwell.
Ms. Maxwell
law enforcement
The arrest and death of Jeffrey Epstein, which led to media frenzy and threats.
Locations (1)
| Location | Context |
|---|---|
|
Mentioned as the location where Ms. Maxwell has family ties, where her spouse is a citizen, and where they lived toge...
|
Relationships (2)
The document describes their 'committed relationship' and how they 'lived a quiet family life together' for over four years. The spouse wrote a letter in support of her.
The document states that the 'intense media frenzy and threats following the arrest and death of Jeffrey Epstein threatened the safety and wellbeing of herself and her family'.
Full Extracted Text
Complete text extracted from the document (2,882 characters)
Case 20-cr-00330-AJN Document 192 Filed 12/14/20 Page 165 of 2045
New Information for the Court’s Consideration
The defense has devoted substantial time and effort to compile information that was not available to Ms. Maxwell at the time of the initial bail hearing that squarely addresses each of the factors the Court considered at that hearing. Because of these efforts, Ms. Maxwell can now present the following additional information in support of her renewed bail application:
• Letter from Ms. Maxwell’s spouse. This letter demonstrates that Ms. Maxwell has powerful family ties to the United States that she will not abandon. It describes the committed relationship between Ms. Maxwell and her spouse, who is a U.S citizen, and how they lived a quiet family life together [REDACTED] in the United States for over four years immediately prior to her arrest. The letter further explains that Ms. Maxwell was forced to leave her family and drop out of the public eye, not because she was trying to evade law enforcement, but because the intense media frenzy and threats following the arrest and death of Jeffrey Epstein threatened the safety and wellbeing of herself and her family, [REDACTED]. For these same reasons, Ms. Maxwell’s spouse did not come forward as a co-signer at the time of the initial hearing. (Ex. A).
• Letters from numerous other friends and family members. These letters from Ms. Maxwell’s other sureties and several family members and friends attest to Ms. Maxwell’s strong, forthright character and their confidence that she will not flee. The sureties also describe the significant financial distress they would suffer if Ms. Maxwell were to violate her bail conditions. (Exs. B-N, W-X).
• Financial report. The financial report, prepared by the accounting firm Macalvins Limited, provides an accounting of Ms. Maxwell’s financial condition from 2015-2020, and discloses (i) all of her own assets, (ii) all assets held in trust, and (iii) all of the assets held by her spouse over that same time period. The report reflects that the total value of assets in all three categories is approximately $22.5 million, which is the amount of the proposed bond. (Ex. O).
• Report from former IRS agent. [REDACTED] a former IRS agent with over 40 years of experience in criminal tax and financial fraud investigations, reviewed the Macalvins report and confirmed that it presents a complete and accurate picture of Ms. Maxwell and her spouse’s assets from 2015-2020. (Ex. P).
• Statement from the person in charge of Ms. Maxwell’s security. This statement rebuts the government’s claim that she attempted to hide from law enforcement at the time of her arrest. (Ex. S).
• Extradition waivers and expert affidavits. To address the Court’s concerns about extradition, Ms. Maxwell will present irrevocable written waivers of her right to
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DOJ-OGR-00001106
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