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734 KB

Extraction Summary

2
People
3
Organizations
1
Locations
3
Events
1
Relationships
5
Quotes

Document Information

Type: Legal filing (memorandum in opposition to detention)
File Size: 734 KB
Summary

This document is page 5 of a Preliminary Statement filed on July 10, 2020, by Ghislaine Maxwell's defense team. It serves as a Memorandum in Opposition to the government's request for detention. The text argues that Maxwell is being unfairly conflated with Jeffrey Epstein, despite having no contact with him for over a decade, and asserts she is not a flight risk as she has lived in the US since 1991 and remained in the country following Epstein's 2019 arrest.

People (2)

Name Role Context
Ghislaine Maxwell Defendant
Submitting a memorandum in opposition to detention; denies charges; claims no contact with Epstein for over a decade.
Jeffrey Epstein Deceased / Former Associate
Indicted July 2019; died in federal custody August 10, 2019; prosecution of him garnered significant public attention.

Organizations (3)

Name Type Context
The Government
Filed a Memorandum in Support of Detention; investigating the case for years.
The Court
The entity Maxwell is appearing before regarding bail.
Media
Focused attention on Epstein and subsequently Maxwell; accused of wrongly trying to substitute her for Epstein.

Timeline (3 events)

1991-01-01
Ghislaine Maxwell began living in the United States.
United States
2019-07-01
Jeffrey Epstein indicted for offenses relating to sexual misconduct.
USA
2019-08-10
Jeffrey Epstein died in federal custody.
Federal Custody

Locations (1)

Location Context
Ms. Maxwell has lived here since 1991.

Relationships (1)

Ghislaine Maxwell Former Associates Jeffrey Epstein
Document states she had 'no contact with Epstein for more than a decade' and media is 'wrongly trying to substitute her for Epstein'.

Key Quotes (5)

"Ghislaine Maxwell is not Jeffrey Epstein."
Source
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Quote #1
"she’d had no contact with Epstein for more than a decade"
Source
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Quote #2
"Ms. Maxwell vigorously denies the charges, intends to fight them, and is entitled to the presumption of innocence."
Source
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Quote #3
"Far from “hiding,” she has lived in the United States since 1991"
Source
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Quote #4
"She should be treated like any other defendant who comes before this Court, including as to bail."
Source
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Quote #5

Full Extracted Text

Complete text extracted from the document (2,140 characters)

Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 5 of 26
PRELIMINARY STATEMENT
Ghislaine Maxwell respectfully submits this Memorandum in Opposition to the
government’s July 2, 2020 Memorandum in Support of Detention (“Gov. Mem.”).
It is difficult to recall a recent case that has garnered more public attention than the
government’s prosecution of Jeffrey Epstein (“Epstein”). In July 2019, Epstein was indicted for
offenses relating to sexual misconduct, amid overwhelming media attention focused on the
nature of the charges and Epstein’s wealth and lifestyle. On August 10, 2019, Epstein died in
federal custody, and the media focus quickly shifted to our client—wrongly trying to substitute
her for Epstein—even though she’d had no contact with Epstein for more than a decade, had
never been charged with a crime or been found liable in any civil litigation, and has always
denied any allegations of claimed misconduct. Many of these stories and online posts were
threatening and harassing to our client and those close to her.
But sometimes the simplest point is the most critical one: Ghislaine Maxwell is not
Jeffrey Epstein. She was not named in the government’s indictment of Epstein in 2019, despite
the fact that the government has been investigating this case for years. Instead, the current
indictment is based on allegations of conduct that allegedly occurred roughly twenty-five years
ago. Ms. Maxwell vigorously denies the charges, intends to fight them, and is entitled to the
presumption of innocence. Far from “hiding,” she has lived in the United States since 1991, has
litigated civil cases arising from her supposed ties to Epstein, and has not left the country even
once since Epstein’s arrest a year ago, even though she was aware of the pending, and highly
publicized, criminal investigation. She should be treated like any other defendant who comes
before this Court, including as to bail. Under the Bail Reform Act, case law in this Circuit and
other circuits, as well as decisions of this Court, Ms. Maxwell should be released on bail, subject
to the strict conditions proposed below.
DOJ-OGR-00001585

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