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724 KB
Extraction Summary
3
People
3
Organizations
0
Locations
1
Events
1
Relationships
4
Quotes
Document Information
Type:
Legal filing / court motion (defense bail argument)
File Size:
724 KB
Summary
This document is page 7 of a legal filing (Case 1:20-cr-00330-AJN) filed on March 23, 2021, arguing for the release of Ghislaine Maxwell on bail. The defense proposes restraining Maxwell's and her spouse's assets under the supervision of a former federal judge to prevent flight. The text also argues that pending pretrial motions—including challenges based on a non-prosecution agreement, constitutional violations, and time-barred Mann Act charges—significantly weaken the government's case.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the bail motion; defense argues her assets should be restrained and that her pretrial motions have merit.
|
| Ms. Maxwell's Spouse | Family Member |
Mentioned in context of assets being overseen alongside Maxwell's.
|
| Former federal District Court judge | Proposed Overseer |
Proposed to supervise Ms. Maxwell's assets to prevent violation of release terms.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Court |
Entity being petitioned to grant bail.
|
|
| The Government |
Opposing party; defense challenges the strength of their case.
|
|
| DOJ |
Department of Justice (indicated in footer Bates stamp).
|
Timeline (1 events)
2021-03-23
Filing of legal document arguing for bail and asserting that pretrial motions could result in dismissal of charges.
Federal District Court
Relationships (1)
Document mentions oversight of 'assets of Ms. Maxwell and her spouse'.
Key Quotes (4)
"Restraining Ms. Maxwell’s assets that are not used to secure the bond and placing them under the supervision of a former federal District Court judge eliminates any concern that such funds could be used to violate the terms of release."Source
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Quote #1
"Ms. Maxwell’s pretrial motions raise serious legal issues that could result in dismissal of charges, if not the entire indictment."Source
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Quote #2
"Among the dozen submissions are motions to dismiss the superseding indictment for breach of the non-prosecution agreement..."Source
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Quote #3
"Other motions seek dismissal of the Mann Act charges as being time-barred and the perjury charges as based on non-perjurious statements."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,046 characters)
Case 1:20-cr-00330-AJN Document 180-1 Filed 03/23/21 Page 7 of 9
accounts and will be entrusted with the authority to oversee the assets of Ms. Maxwell and her
spouse, as described above.
spouse, as described above.
Restraining Ms. Maxwell’s assets that are not used to secure the bond and placing them under
the supervision of a former federal District Court judge eliminates any concern that such funds
could be used to violate the terms of release.
the supervision of a former federal District Court judge eliminates any concern that such funds
could be used to violate the terms of release.
II. Ms. Maxwell’s Pretrial Motions Raise Substantial Legal and Factual Issues
That Could Result in Dismissal of Some or All of the Charges Against Her
That Could Result in Dismissal of Some or All of the Charges Against Her
In addition to the new conditions proposed above, the numerous substantive pretrial
motions now before the Court amply challenge the purported strength of the government’s case.
Ms. Maxwell’s pretrial motions raise serious legal issues that could result in dismissal of
charges, if not the entire indictment. Among the dozen submissions are motions to dismiss the
superseding indictment for breach of the non-prosecution agreement, for pre-indictment delay,
and for being based on improperly obtained evidence in violation of Ms. Maxwell’s
constitutional rights under the Fifth and Sixth the Amendments. Other motions seek dismissal of
the Mann Act charges as being time-barred and the perjury charges as based on non-perjurious
statements. These motions are substantial with a likelihood of success on the merits. These
motions cast substantial doubt on the alleged strength of the government’s case and warrant
granting bail on the conditions proposed.
motions now before the Court amply challenge the purported strength of the government’s case.
Ms. Maxwell’s pretrial motions raise serious legal issues that could result in dismissal of
charges, if not the entire indictment. Among the dozen submissions are motions to dismiss the
superseding indictment for breach of the non-prosecution agreement, for pre-indictment delay,
and for being based on improperly obtained evidence in violation of Ms. Maxwell’s
constitutional rights under the Fifth and Sixth the Amendments. Other motions seek dismissal of
the Mann Act charges as being time-barred and the perjury charges as based on non-perjurious
statements. These motions are substantial with a likelihood of success on the merits. These
motions cast substantial doubt on the alleged strength of the government’s case and warrant
granting bail on the conditions proposed.
III. The Court Should Grant Bail
Under the Bail Reform Act of 1984, a defendant must be released on personal
recognizance or unsecured personal bond unless the judicial officer determines “that such release
will not reasonably assure the appearance of the person as required or will endanger the safety of
any other person or the community.” 18 U.S.C. § 3142(b). The enhanced bail package proposed
by Ms. Maxwell contains financial burdens and a combination of restrictions that reasonably
recognizance or unsecured personal bond unless the judicial officer determines “that such release
will not reasonably assure the appearance of the person as required or will endanger the safety of
any other person or the community.” 18 U.S.C. § 3142(b). The enhanced bail package proposed
by Ms. Maxwell contains financial burdens and a combination of restrictions that reasonably
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