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634 KB

Extraction Summary

4
People
3
Organizations
1
Locations
3
Events
1
Relationships
4
Quotes

Document Information

Type: Legal filing (defense memorandum in support of bail application)
File Size: 634 KB
Summary

This document is page 9 of a legal filing (Document 103) from December 23, 2020, in the case against Ghislaine Maxwell. The text argues that Maxwell and her spouse only discussed divorce prior to her arrest to protect him from 'terrible consequences,' not because the relationship was failing, and asserts that the spouse is willing to co-sign her bond. It also defends Maxwell's financial disclosures, stating she has pledged all her and her spouse's assets and that the government has not successfully challenged the accuracy of her financial report.

People (4)

Name Role Context
Ghislaine Maxwell Defendant
Discussed divorce to protect spouse; pledging assets for bond.
Spouse (Unnamed in text/Redacted) Spouse/Potential Co-signer
Discussed divorce; willing to co-sign bond; described as a powerful tie to the country.
The Government Prosecution
Opposing bail; arguing Maxwell deceived the court.
AJN Judge
Initials in case number (Alison J. Nathan).

Organizations (3)

Name Type Context
Pretrial Services
Agency to whom assets were disclosed.
The Court
Previously denied bail.
DOJ
Indicated in Bates stamp (DOJ-OGR).

Timeline (3 events)

2020-12-23
Filing of Document 103
Court
Defense Counsel
Prior to arrest
Discussions regarding divorce between Maxwell and spouse.
Unknown
Ms. Maxwell Spouse
Weeks following initial bail hearing
Change in circumstance leading to decision not to divorce (context heavily redacted).
Unknown
Ms. Maxwell Spouse

Locations (1)

Location Context
Referenced regarding Maxwell's ties to the US.

Relationships (1)

Ms. Maxwell Spousal Spouse
Text discusses their marriage, potential divorce discussions to protect him, and his willingness to co-sign her bond.

Key Quotes (4)

"Prior to her arrest, Ms. Maxwell and her spouse had discussed the idea of getting a divorce as an additional way to create distance between Ms. Maxwell and her spouse to protect him... from the terrible consequences of being associated with her."
Source
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Quote #1
"She and her spouse therefore had no reason to continue discussing divorce, which neither of them wanted in the first place."
Source
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Quote #2
"Ms. Maxwell Has Thoroughly Disclosed Her Finances and Pledged All of Her and Her Spouse’s Assets in Support of Her Bond"
Source
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Quote #3
"The government’s assertion that Ms. Maxwell must not have a close relationship with [REDACTED] is particularly callous and belied by the facts."
Source
DOJ-OGR-00002215(1).jpg
Quote #4

Full Extracted Text

Complete text extracted from the document (1,816 characters)

Case 1:20-cr-00330-AJN Document 103 Filed 12/23/20 Page 9 of 15
mistaken. Prior to her arrest, Ms. Maxwell and her spouse had discussed the idea of getting
a divorce as an additional way to create distance between Ms. Maxwell and her spouse to
protect him [REDACTED] from the terrible consequences of being associated with her.
Nevertheless, in the weeks following the initial bail hearing, [REDACTED]
[REDACTED]
[REDACTED] She and her spouse therefore had no reason to continue
discussing divorce, which neither of them wanted in the first place. Nor was there any
reason for her spouse to refrain from stepping forward as a co-signer. In sum, the
government has offered nothing but unsupported innuendo to suggest that Ms. Maxwell’s
relationship with her spouse [REDACTED] is not a powerful tie to this country.
The government’s assertion that Ms. Maxwell must not have a close relationship
with [REDACTED] is particularly callous
and belied by the facts. (Gov. Mem. at 14). As her spouse explains, [REDACTED]
[REDACTED] (Ex. A ¶ 12).
[REDACTED]
[REDACTED]
B. Ms. Maxwell Has Thoroughly Disclosed Her Finances and Pledged All of
Her and Her Spouse’s Assets in Support of Her Bond
The government’s attempts to rebut the financial condition report are unavailing.
Significantly, the government does not contest the accuracy of the report, nor the
voluminous supporting documentation. In fact, the government has proffered nothing that
calls into question the report’s detailed account of Ms. Maxwell and her spouse’s assets for
the last five years, which addresses one of the Court’s principal reasons for denying bail.
Rather than question the report itself, the government attempts to argue that Ms.
Maxwell deceived the Court and Pretrial Services about her assets. (Gov. Mem. at 22-23).
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