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723 KB

Extraction Summary

5
People
2
Organizations
0
Locations
5
Events
3
Relationships
5
Quotes

Document Information

Type: Legal document
File Size: 723 KB
Summary

This legal document, filed on March 23, 2021, argues that the government's case against Ms. Maxwell is weakening, thereby diminishing her flight risk. The filing points to several weaknesses, including a 2007 Non-Prosecution Agreement with Jeffrey Epstein that may immunize Maxwell, the government's concession that it cannot prove Maxwell or Epstein caused 'Accuser-3' to travel, and evidence that prosecutors misled a judge. The document suggests that despite the government's escalating claims about her flight risk, the deteriorating case against her warrants a reevaluation of her detention.

People (5)

Name Role Context
Ms. Maxwell Defendant
The subject of the legal filing, whose period of detention and flight risk are being discussed. She is alleged to be ...
Jeffrey Epstein
Mentioned in relation to a 2007 Non-Prosecution Agreement that allegedly immunizes his co-conspirators. Also mentione...
Accuser-3 Accuser/Victim
An individual the government allegedly cannot prove was caused to travel by Maxwell or Epstein. The footnote identifi...
Minor Victim-3 Victim
The identifier for "Accuser-3" in the official Indictment, as stated in a footnote.
federal judge Judge
Allegedly misled by government prosecutors to obtain evidence against Ms. Maxwell.

Organizations (2)

Name Type Context
The Government government agency
The prosecuting party in the case against Ms. Maxwell. The document argues that the strength of the government's case...
The Court government agency
The judicial body where pretrial motions are pending in Ms. Maxwell's case.

Timeline (5 events)

2007
A Non-Prosecution Agreement was entered into by Jeffrey Epstein.
Ms. Maxwell's period of detention has passed the nine-month mark.
Ms. Maxwell challenged the strength of the government's case in pretrial motions pending before the Court.
Alleged sex acts between Epstein and Accuser-3 while Accuser-3 was underage.
Government prosecutors allegedly misled a federal judge to obtain evidence against Ms. Maxwell.
government prosecutors federal judge

Relationships (3)

Ms. Maxwell co-conspirators (alleged) Jeffrey Epstein
The document states that Ms. Maxwell is argued to be protected by a Non-Prosecution Agreement that immunizes 'any potential co-conspirators of Epstein'.
Ms. Maxwell defendant-accuser Accuser-3
The document discusses charges against Ms. Maxwell related to Accuser-3, but claims the government cannot prove Maxwell caused Accuser-3 to travel.
Jeffrey Epstein abuser-victim (alleged) Accuser-3
The document mentions that Accuser-3 allegedly engaged in sex acts with Epstein while she was underage.

Key Quotes (5)

"plain [ ] risk of flight"
Source
— The Government (The government's initial assessment of Ms. Maxwell's flight risk.)
DOJ-OGR-00002788.jpg
Quote #1
"substantial and actual risk of flight"
Source
— The Government (An upgraded assessment of Ms. Maxwell's flight risk.)
DOJ-OGR-00002788.jpg
Quote #2
"serious flight of risk"
Source
— The Government (A further upgraded assessment of Ms. Maxwell's flight risk.)
DOJ-OGR-00002788.jpg
Quote #3
"extreme risk of flight"
Source
— The Government (The government's current assessment of Ms. Maxwell's flight risk.)
DOJ-OGR-00002788.jpg
Quote #4
"any potential co-conspirators of Epstein"
Source
DOJ-OGR-00002788.jpg
Quote #5

Full Extracted Text

Complete text extracted from the document (2,114 characters)

Case 1:20-cr-00330-PAE Document 171 Filed 03/23/21 Page 8 of 18
Conceded Problems Undermine the Strength of the Government’s Case
As Ms. Maxwell’s period of detention passes the nine-month mark, the government has
continuously upgraded Ms. Maxwell from a “plain [ ] risk of flight” to a “substantial and
actual risk of flight” to a “serious flight of risk” and now to an “extreme risk of flight.” (Dkt.
165 at 1.) Ironically, her level of flight risk increases as the strength of government’s case
against her diminishes. Ms. Maxwell has challenged the strength of the government’s case
in pretrial motions pending before the Court. Among other things, Ms. Maxwell has
persuasively argued that the Non-Prosecution Agreement entered into by Jeffrey Epstein in
2007, which immunizes “any potential co-conspirators of Epstein,” bars Ms. Maxwell’s
prosecution in this case, and that the counts charging her with alleged sexual abuse are
time-barred.
The government’s response to Ms. Maxwell’s pretrial motions shines further light
of the weaknesses of its case. For example, the government concedes it cannot establish that
either Ms. Maxwell or Epstein ever caused, or sought to cause, Accuser-3⁴ to travel while she
was a minor or that she was underage when she allegedly engaged in sex acts with Epstein.
(See Opp.162-65 & fn. 57-58.)⁵ Hence, her allegations cannot support the conspiracies charged
in the Indictment, leaving the government with only two witnesses to prove the charges against
Ms. Maxwell. More importantly, in connection with the government’s response, it
produced documents indicating that government prosecutors misled a federal judge to
obtain evidence against Ms. Maxwell (see, e.g.,. Opp. Ex. 4-7) - a shocking revelation that
undermines the viability of the perjury counts, not to mention the integrity of the entire
⁴ Accuser-3 is identified in the Indictment as “Minor Victim-3.”
⁵ “Opp.” references are to page numbers of the Government’s Omnibus Memorandum in Opposition to Defendant’s
Pre-Trial Motions, dated February 26, 2021 and not yet publicly filed.
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