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510 KB

Extraction Summary

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

Document Information

Type: Court filing / government memorandum regarding detention
File Size: 510 KB
Summary

This page is from a government filing (Case 1:20-cr-00330-AJN, U.S. v. Ghislaine Maxwell) dated July 2, 2020, arguing for the defendant's detention pending trial. The government argues that despite COVID-19 concerns, the defendant should remain at the Metropolitan Detention Center (MDC) like other inmates, citing her significant assets, foreign ties, and history of evading detection as flight risks. The document also introduces an argument based on the Crime Victims' Rights Act (CVRA), noting that victims and their counsel have been contacted and seek her detention.

People (4)

Name Role Context
The Defendant Defendant (Ghislaine Maxwell based on case number)
Subject of the detention hearing; noted to have significant assets, foreign ties, and ability to evade detection.
The Government Prosecution
Arguing for the detention of the defendant.
Victims Crime Victims
Seeking the detention of the defendant; rights protected under CVRA.
Counsel for one victim Legal Counsel
Conveyed views to the Government regarding the detention application.

Timeline (1 events)

2020-07-02
Filing of Government Memorandum regarding detention
Court

Locations (1)

Location Context
Facility where the Government proposes detaining the defendant pending trial.

Relationships (2)

The Government Legal Adversaries The Defendant
Government urges the Court to detain her.
The Defendant Perpetrator/Victim Victims
Text refers to 'victims of the defendant’s crimes'.

Key Quotes (4)

"This defendant should not be granted the special treatment she requests."
Source
DOJ-OGR-00000988.jpg
Quote #1
"The defendant faces a presumption of detention, she has significant assets and foreign ties, she has demonstrated her ability to evade detection, and the victims of the defendant’s crimes seek her detention."
Source
DOJ-OGR-00000988.jpg
Quote #2
"Because there is no set of conditions short of incarceration that can reasonably assure the defendant’s appearance, the Government urges the Court to detain her."
Source
DOJ-OGR-00000988.jpg
Quote #3
"Counsel for one victim has already conveyed to the Government that"
Source
DOJ-OGR-00000988.jpg
Quote #4

Full Extracted Text

Complete text extracted from the document (2,063 characters)

Case 1:20-cr-00330-AJN Document 20 Filed 07/02/20 Page 4 of 20
Finally, the Government recognizes that the COVID-19 pandemic is – and should be – a
relevant factor for the Court and the parties in this case. However, the Bureau of Prisons (“BOP”)
is taking very significant steps to address that concern, and the defendant has offered no reason
why she should be treated any differently from the many defendants who are currently detained at
the Metropolitan Detention Center (“MDC”) pending trial, including defendants who have medical
conditions that place them at heightened risk. Inmates at the MDC are able to assist in their own
defense, especially long before trial, through established policies and procedures applicable to
every pretrial detainee. This defendant should not be granted the special treatment she requests.
The defendant faces a presumption of detention, she has significant assets and foreign ties,
she has demonstrated her ability to evade detection, and the victims of the defendant’s crimes seek
her detention. Because there is no set of conditions short of incarceration that can reasonably
assure the defendant’s appearance, the Government urges the Court to detain her.
ARGUMENT
Each of the relevant factors to be considered as to flight risk – the nature and circumstances
of the offense, the strength of the evidence, and the history and characteristics of the defendant –
weigh strongly in favor of detention, and the defendant’s proposed package would do absolutely
nothing to mitigate those risks.
I. The Defendant’s Victims Seek Detention
As the Court is aware, pursuant to the Crime Victims’ Rights Act (“CVRA”), a crime
victim has the right to be reasonably heard at certain public proceedings in the district court,
including proceedings involving release. 18 U.S.C. § 3771(a)(4). Consistent with that
requirement, the Government has been in contact with victims and their counsel in connection with
its application for detention. Counsel for one victim has already conveyed to the Government that
3
DOJ-OGR-00000988

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