DOJ-OGR-00001982.jpg
927 KB
Extraction Summary
5
People
3
Organizations
1
Locations
3
Events
2
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
927 KB
Summary
This legal document is part of a renewed bail application for Ms. Maxwell, submitted by her defense team. It presents new evidence to the Court, including letters of support from her spouse and friends, a detailed financial report from Macalvins Limited showing assets of approximately $22.5 million for a proposed bond, and statements to counter the government's narrative that she was a flight risk. The defense argues this new information, unavailable at the initial hearing, demonstrates her strong ties to the U.S. and justifies her release on bail.
People (5)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
The central subject of the document, seeking a renewed bail application.
|
| Ms. Maxwell's spouse | Spouse |
Mentioned as a U.S. citizen who wrote a letter in support of Ms. Maxwell's bail application, describing their relatio...
|
| Jeffrey Epstein |
Mentioned in the context of threats following his arrest and death, which reportedly caused Ms. Maxwell to drop out o...
|
|
| former IRS agent | Financial expert |
An unnamed former IRS agent who reviewed and confirmed the accuracy of a financial report on Ms. Maxwell's and her sp...
|
| person in charge of Ms. Maxwell's security | Head of security |
An unnamed individual who provided a statement rebutting the government's claim that Ms. Maxwell attempted to hide fr...
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Court | government agency |
The judicial body being addressed in the bail application.
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| Macalvins Limited | company |
An accounting firm that prepared a financial report on Ms. Maxwell's financial condition from 2015-2020.
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| IRS | government agency |
Mentioned as the former employer of an agent who reviewed financial reports for the defense.
|
Timeline (3 events)
The initial bail hearing for Ms. Maxwell, where certain information was not available to the defense.
The arrest of Ms. Maxwell, prior to which she and her spouse lived in the U.S. for over four years.
Ms. Maxwell
law enforcement
The arrest and death of Jeffrey Epstein, which led to a media frenzy and threats against Ms. Maxwell and her family.
Locations (1)
| Location | Context |
|---|---|
|
Mentioned as the country where Ms. Maxwell has family ties, where her spouse is a citizen, and where they lived toget...
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Relationships (2)
The document describes them as spouses in a 'committed relationship' who 'lived a quiet family life together' for over four years.
The document states that the 'intense media frenzy and threats following the arrest and death of Jeffrey Epstein threatened the safety and wellbeing of herself and her family,' implying a known connection that drew media attention.
Full Extracted Text
Complete text extracted from the document (2,846 characters)
Case 1:20-cr-00330-AJN Document 97 Filed 12/14/20 Page 10 of 45
New Information for the Court's Consideration
The defense has devoted substantial time and effort to compile information that was not available to Ms. Maxwell at the time of the initial bail hearing that squarely addresses each of the factors the Court considered at that hearing. Because of these efforts, Ms. Maxwell can now present the following additional information in support of her renewed bail application:
• Letter from Ms. Maxwell's spouse. This letter demonstrates that Ms. Maxwell has powerful family ties to the United States that she will not abandon. It describes the committed relationship between Ms. Maxwell and her spouse, who is a U.S citizen, and how they lived a quiet family life together in the United States for over four years immediately prior to her arrest. The letter further explains that Ms. Maxwell was forced to leave her family and drop out of the public eye, not because she was trying to evade law enforcement, but because the intense media frenzy and threats following the arrest and death of Jeffrey Epstein threatened the safety and wellbeing of herself and her family, For these same reasons, Ms. Maxwell’s spouse did not come forward as a co-signer at the time of the initial hearing. (Ex. A).
• Letters from numerous other friends and family members. These letters from Ms. Maxwell's other sureties and several family members and friends attest to Ms. Maxwell's strong, forthright character and their confidence that she will not flee. The sureties also describe the significant financial distress they would suffer if Ms. Maxwell were to violate her bail conditions. (Exs. B-N, W-X).
• Financial report. The financial report, prepared by the accounting firm Macalvins Limited, provides an accounting of Ms. Maxwell's financial condition from 2015-2020, and discloses (i) all of her own assets, (ii) all assets held in trust, and (iii) all of the assets held by her spouse over that same time period. The report reflects that the total value of assets in all three categories is approximately $22.5 million, which is the amount of the proposed bond. (Ex. O).
• Report from former IRS agent. a former IRS agent with over 40 years of experience in criminal tax and financial fraud investigations, reviewed the Macalvins report and confirmed that it presents a complete and accurate picture of Ms. Maxwell and her spouse's assets from 2015-2020. (Ex. P).
• Statement from the person in charge of Ms. Maxwell's security. This statement rebuts the government’s claim that she attempted to hide from law enforcement at the time of her arrest. (Ex. S).
• Extradition waivers and expert affidavits. To address the Court's concerns about extradition, Ms. Maxwell will present irrevocable written waivers of her right to
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DOJ-OGR-00001982
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