DOJ-OGR-00001236.jpg
715 KB
Extraction Summary
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People
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Organizations
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Locations
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Events
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Relationships
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Quotes
Document Information
Type:
Legal motion / court filing (bail application)
File Size:
715 KB
Summary
This document is page 4 of a legal filing (Case 1:20-cr-00330-AJN) dated December 28, 2020, arguing for Ghislaine Maxwell's release on bail. Her defense proposes two additional conditions to assure the court she is not a flight risk, specifically offering to formally renounce her citizenships in France and the United Kingdom and surrender all passports. The defense argues that giving up citizenship, described as a 'precious and priceless asset,' demonstrates her commitment to appearing in court.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the bail hearing; proposing additional restrictions including renouncing citizenship to secure release.
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| Rowe | Case Citation Subject |
Referenced in case law (United States v. Rowe) regarding reconsideration of release orders.
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| Petrov | Case Citation Subject |
Referenced in case law (United States v. Petrov) regarding court authority for bail reconsideration.
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Organizations (2)
| Name | Type | Context |
|---|---|---|
| United States District Court (S.D.N.Y.) |
The court handling the case (Southern District of New York).
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| Department of Justice (DOJ) |
Indicated by the Bates stamp 'DOJ-OGR-00001236'.
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Timeline (2 events)
2020-12-28
Filing of Document 130-1 proposing additional bail conditions.
S.D.N.Y.
Ghislaine Maxwell
Defense Attorneys
Locations (3)
| Location | Context |
|---|---|
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Country of citizenship Ms. Maxwell is offering to renounce.
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Country of citizenship Ms. Maxwell is offering to renounce.
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Jurisdiction of the legal proceedings.
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Key Quotes (4)
"Ms. Maxwell is willing to formally renounce her foreign citizenships in France and the United Kingdom."Source
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Quote #1
"Citizenship is a precious and priceless asset."Source
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Quote #2
"Renunciation of UK citizenship can be accomplished immediately upon granting of bail."Source
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Quote #3
"Ms. Maxwell now proposes two additional restrictions that eliminate any means or opportunity that she may have to leave the country."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,039 characters)
Case 1:20-cr-00330-AJN Document 130-1 Filed 12/28/20 Page 4 of 9
I. The Proposed Additional Bail Conditions Will Reasonably Assure Ms. Maxwell’s Appearance in Court
As set forth above, Ms. Maxwell now proposes two additional restrictions that eliminate any means or opportunity that she may have to leave the country. The Court should therefore reconsider its earlier ruling and grant bail under the proposed conditions. See United States v. Rowe, No. 02 CR. 756 LMM, 2003 WL 21196846, at *1 (S.D.N.Y. May 21, 2003) (“[A] release order may be reconsidered even where the evidence proffered on reconsideration was known to the movant at the time of the original hearing.”); see also United States v. Petrov, No. 15-CR-66- LTS, 2015 WL 11022886, at *3 (S.D.N.Y. Mar. 26, 2015) (noting “Court’s inherent authority for reconsideration of the Court’s previous bail decision”).
A. Renunciation of Foreign Citizenship
To demonstrate her commitment to abide by her conditions of release and to provide further assurance to the Court that she will not attempt to leave the country, Ms. Maxwell is willing to formally renounce her foreign citizenships in France and the United Kingdom. Should the Court feel this drastic condition is necessary, the required documents will be submitted to the appropriate authorities. Moreover, as a standard condition of bail, all of Ms. Maxwell’s passports will be surrendered to the government and no further application will be made.
If the Court deems it a necessary condition of release, Ms. Maxwell will formally commence the procedure to renounce her foreign citizenship. The requisite paperwork is in the process of being completed. Renunciation of UK citizenship can be accomplished immediately upon granting of bail. The process of renouncing her French citizenship, while not immediate, may be expedited.
Citizenship is a precious and priceless asset. Ms. Maxwell’s decision to give up citizenship from the county of her birth and the country of her upbringing demonstrates her
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DOJ-OGR-00001236
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