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648 KB
Extraction Summary
2
People
2
Organizations
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Locations
1
Events
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Relationships
4
Quotes
Document Information
Type:
Legal filing (reply brief - appeal)
File Size:
648 KB
Summary
This document is page 3 of a legal reply brief filed on April 19, 2021, in Case 21-770 (associated with Ghislaine Maxwell). The defense argues that the lower court did not conduct a 'lengthy bail hearing' and that the Government presented no actual evidence, relying solely on the text of the Indictment to argue the strength of the case and flight risk. The filing contends the court erred by accepting the Indictment itself as proof of the strength of evidence.
People (2)
| Name | Role | Context |
|---|---|---|
| The Defendant | Accused |
Subject of the bail hearing; described by government as having 'incredibly strong incentive to flee'
|
| The Government | Prosecution |
Argued against bail; cited the Indictment rather than presenting new evidence
|
Timeline (1 events)
Unknown (Prior to 04/19/2021)
Relationships (1)
Government arguing for detention based on flight risk; Defendant appealing.
Key Quotes (4)
"that the presumption of innocence is more than mere words on a page."Source
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Quote #1
"The Government did not present any actual evidence at this brief hearing."Source
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Quote #2
"The court erred in agreeing that the Indictment itself demonstrates strength."Source
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Quote #3
"At no point did the Government introduce or even proffer any actual evidence."Source
DOJ-OGR-00001375.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (1,403 characters)
Case 21-770, Document 57, 04/19/2021, 3080288, Page3 of 30
that the presumption of innocence is more than mere words on a page.
This Reply responds to the arguments the Government does raise:
This Reply responds to the arguments the Government does raise:
1. The Court did not conduct a "lengthy bail hearing." Resp.¶ 2.
The transcript of the video arraignment and bail hearing spans only 91
pages, with the bail arguments on pages 22-79. The Government did not
present any actual evidence at this brief hearing. Br.7-8,19-21. During the
bail hearing, each time the Government mentioned the strength of its
case, it cited to the Indictment. See, e.g., Ex.D, p.24 ("Turning first to the
... strength of the evidence, the indictment in this case arises ... . The
indictment further charges that ..."); pg. 25 ("The indictment makes plain
... it was an ongoing scheme ... Given the strength of the government's
evidence ... there is an incredibly strong incentive for the defendant to flee
..."). The court erred in agreeing that the Indictment itself demonstrates
strength. Id. at 82 ("[I]t is appropriate to consider the strength of the
evidence proffered by the government in assessing risk of flight. The
government's evidence at this early juncture of the case appears strong.
Although the charged conduct took place many years ago, the indictment
describes ..."). At no point did the Government introduce or even proffer
any actual evidence.
The transcript of the video arraignment and bail hearing spans only 91
pages, with the bail arguments on pages 22-79. The Government did not
present any actual evidence at this brief hearing. Br.7-8,19-21. During the
bail hearing, each time the Government mentioned the strength of its
case, it cited to the Indictment. See, e.g., Ex.D, p.24 ("Turning first to the
... strength of the evidence, the indictment in this case arises ... . The
indictment further charges that ..."); pg. 25 ("The indictment makes plain
... it was an ongoing scheme ... Given the strength of the government's
evidence ... there is an incredibly strong incentive for the defendant to flee
..."). The court erred in agreeing that the Indictment itself demonstrates
strength. Id. at 82 ("[I]t is appropriate to consider the strength of the
evidence proffered by the government in assessing risk of flight. The
government's evidence at this early juncture of the case appears strong.
Although the charged conduct took place many years ago, the indictment
describes ..."). At no point did the Government introduce or even proffer
any actual evidence.
3
DOJ-OGR-00001375
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