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720 KB
Extraction Summary
3
People
4
Organizations
1
Locations
1
Events
2
Relationships
3
Quotes
Document Information
Type:
Court filing (defense reply memorandum regarding bail application)
File Size:
720 KB
Summary
This document is page 7 of a legal filing (Document 171) dated March 23, 2021, in the case against Ghislaine Maxwell. The defense argues for her release on bail, claiming she has transparently disclosed her assets (including those held jointly with her spouse) and refuting the government's claim that her wealth makes her a flight risk. A footnote strongly condemns the government's suggestion that defense attorneys would allow escrowed legal funds to be used to support Maxwell as a fugitive.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the bail application; defense argues she is not a flight risk and has disclosed assets.
|
| The Spouse | Family member |
Mentioned as holding joint assets with Ms. Maxwell.
|
| New York Counsel | Defense Attorneys |
Attorneys defending Maxwell; they take offense at the government's suggestion they would help her flee using escrow f...
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Pretrial Services |
Agency that posed questions to Maxwell regarding her personal assets.
|
|
| The Government |
Prosecution/DOJ; opposing the bail application.
|
|
| Unnamed Accounting Firm |
Described as 'highly respected'; vetted Maxwell's financial documents.
|
|
| The Court |
The judicial body overseeing the case (SDNY).
|
Locations (1)
| Location | Context |
|---|---|
|
Implied jurisdiction where counsel practices ('this district').
|
Relationships (2)
Reference to assets 'jointly held with the spouse'.
Counsel takes 'umbrage' at government assertions; calls government arguments 'inane' and 'frivolous'.
Key Quotes (3)
"The government challenges the Court by inanely stating that if 'the only way to keep the defendant from using her assets to flee is to take away control of her assets, then she is too great a risk to release.'"Source
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Quote #1
"To suggest that defense counsel would become accomplices to a violation of a court order shows utter disrespect for Ms. Maxwell’s defense team."Source
DOJ-OGR-00002787.jpg
Quote #2
"New York counsel... take umbrage at the government’s callous assertion."Source
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Quote #3
Full Extracted Text
Complete text extracted from the document (2,223 characters)
Case 1:20-cr-00330-PAE Document 171 Filed 03/23/21 Page 7 of 18
deprivation, and other conditions adverse to her physical health and mental well-being, Ms.
Maxwell responded appropriately and accurately to questions posed by Pretrial Services which
were restricted to her personal assets. Since then, financial documents - collected and
professionally vetted by a highly respected accounting firm – have been submitted to the
government and the Court and provide full details and supporting documentation concerning
Ms. Maxwell’s personal assets and those jointly held with the spouse. Further, no valid
challenge has been made to those submissions.
Maxwell responded appropriately and accurately to questions posed by Pretrial Services which
were restricted to her personal assets. Since then, financial documents - collected and
professionally vetted by a highly respected accounting firm – have been submitted to the
government and the Court and provide full details and supporting documentation concerning
Ms. Maxwell’s personal assets and those jointly held with the spouse. Further, no valid
challenge has been made to those submissions.
The government challenges the Court by inanely stating that if “the only way to keep
the defendant from using her assets to flee is to take away control of her assets, then she is too
great a risk to release.” (Dkt.165 at 8.) This statement is fundamentally illogical as it
undermines most conditions of release. For example, the same could be said of electronic
monitoring – i.e., if the only way to keep a defendant from fleeing the jurisdiction is to place
him on home confinement with electronic monitoring, then he is too great a flight risk to
release.³ The Court should readily dismiss this frivolous argument. Under the Bail Reform Act,
if there are appropriate conditions for release, bail should be granted. The conditions
collectively proposed in the previous and present bail applications provide ample assurance that
Ms. Maxwell will be present at trial.
the defendant from using her assets to flee is to take away control of her assets, then she is too
great a risk to release.” (Dkt.165 at 8.) This statement is fundamentally illogical as it
undermines most conditions of release. For example, the same could be said of electronic
monitoring – i.e., if the only way to keep a defendant from fleeing the jurisdiction is to place
him on home confinement with electronic monitoring, then he is too great a flight risk to
release.³ The Court should readily dismiss this frivolous argument. Under the Bail Reform Act,
if there are appropriate conditions for release, bail should be granted. The conditions
collectively proposed in the previous and present bail applications provide ample assurance that
Ms. Maxwell will be present at trial.
____________________________
³ Moreover, in an effort to further obfuscate the merits of Ms. Maxwell’s bail application, the government
desperately argues that funds for legal services, presently held in attorney escrow accounts, would be
released and made available to support Ms. Maxwell as a fugitive. To suggest that defense counsel would
become accomplices to a violation of a court order shows utter disrespect for Ms. Maxwell’s defense team.
In particular, New York counsel, who have spent the entirety of their legal careers practicing in this district
and establishing well-respected reputations among the bench and bar, take umbrage at the government’s
callous assertion.
³ Moreover, in an effort to further obfuscate the merits of Ms. Maxwell’s bail application, the government
desperately argues that funds for legal services, presently held in attorney escrow accounts, would be
released and made available to support Ms. Maxwell as a fugitive. To suggest that defense counsel would
become accomplices to a violation of a court order shows utter disrespect for Ms. Maxwell’s defense team.
In particular, New York counsel, who have spent the entirety of their legal careers practicing in this district
and establishing well-respected reputations among the bench and bar, take umbrage at the government’s
callous assertion.
6
DOJ-OGR-00002787
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