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737 KB
Extraction Summary
4
People
3
Organizations
3
Locations
3
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal defense memorandum / bail application
File Size:
737 KB
Summary
This document is a page from a legal defense filing arguing against the pre-trial detention of Ghislaine Maxwell. It outlines her background, emphasizing her US citizenship since 1991 and strong family ties in the US to counter the government's argument that she is a flight risk. The defense disputes the government's claim that she was 'hiding,' asserting she was in regular contact with authorities through counsel since Epstein's arrest.
People (4)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the detention hearing; described as 58, naturalized US citizen, also citizen of UK and France.
|
| Jeffrey Epstein | Associate/Co-conspirator |
Mentioned in relation to his July 2019 indictment and arrest.
|
| Maxwell's Siblings | Family |
Six siblings who have maintained extremely close relationships with her.
|
| Maxwell's Sisters (Two) | Family |
Specifically noted as residing in the US with their children; Maxwell is especially close to them.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Oxford University |
Institution where Ms. Maxwell graduated.
|
|
| The Government (US) |
Prosecution arguing for detention based on flight risk.
|
|
| DOJ (Department of Justice) |
Indicated by the footer stamp 'DOJ-OGR'.
|
Timeline (3 events)
Locations (3)
| Location | Context |
|---|---|
|
Ms. Maxwell's residence since 1991; location of two sisters.
|
|
|
Ms. Maxwell's birthplace and country of citizenship.
|
|
|
Country of education, childhood, and citizenship.
|
Relationships (2)
Document references the aftermath of Epstein's July 2019 indictment and arrest.
She is especially close to two of her sisters and their children, all of whom reside in the United States.
Key Quotes (3)
"Ms. Maxwell's family and friends have remained committed to her because they do not believe the allegations against her, which do not match the person they have known for decades."Source
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Quote #1
"the government speculates that Ms. Maxwell was 'hiding' from law enforcement during the pendency of the investigation, even though she has been in regular contact with the government, through counsel, since Epstein's arrest."Source
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Quote #2
"Ms. Maxwell poses a flight risk because she supposedly lacks ties to the United States; is a citizen of the United Kingdom and France, as well as a citizen of the United States"Source
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Quote #3
Full Extracted Text
Complete text extracted from the document (2,196 characters)
Case 1:20-cr-00330-AJN Document 20-2 Filed 04/01/21 Page 3 of 20
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 3 of 26
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 3 of 26
Background. Ms. Maxwell, 58, is a naturalized U.S. citizen who has resided in the
United States since 1991. She is also a citizen of France, where she was born, and of the United
Kingdom, where she was educated and spent her childhood and formative years. Ms. Maxwell
graduated from Oxford University. She moved to the United States in 1991, and has lived in this
country ever since that time. Ms. Maxwell has maintained extremely close relationships with her
six siblings and her nephews and nieces. They all stood by her in the aftermath of the July 2019
indictment of Epstein and continue to stand by her now. She is especially close to two of her
sisters and their children, all of whom reside in the United States. Ms. Maxwell also has
numerous friends in the United States who themselves have children, and she is a godmother to
many of them. Ms. Maxwell’s family and friends have remained committed to her because they
do not believe the allegations against her, which do not match the person they have known for
decades.
United States since 1991. She is also a citizen of France, where she was born, and of the United
Kingdom, where she was educated and spent her childhood and formative years. Ms. Maxwell
graduated from Oxford University. She moved to the United States in 1991, and has lived in this
country ever since that time. Ms. Maxwell has maintained extremely close relationships with her
six siblings and her nephews and nieces. They all stood by her in the aftermath of the July 2019
indictment of Epstein and continue to stand by her now. She is especially close to two of her
sisters and their children, all of whom reside in the United States. Ms. Maxwell also has
numerous friends in the United States who themselves have children, and she is a godmother to
many of them. Ms. Maxwell’s family and friends have remained committed to her because they
do not believe the allegations against her, which do not match the person they have known for
decades.
The Government’s Position. The government has the burden of persuasion in showing
that detention is warranted, and that there are no conditions or combination of conditions that
will secure a defendant’s appearance in court. In seeking to carry this burden, the government
relies on the presumption of detention in 18 U.S.C. § 3142(e)(3)(E), and argues that Ms.
Maxwell poses a flight risk because she supposedly lacks ties to the United States; is a citizen of
the United Kingdom and France, as well as a citizen of the United States, and has passports for
each country; has traveled internationally in the past; and has financial means. And echoing
recent media stories, the government speculates that Ms. Maxwell was “hiding” from law
enforcement during the pendency of the investigation, even though she has been in regular
contact with the government, through counsel, since Epstein’s arrest. Finally, the government
argues that the nature and circumstances of the offense and the weight of the evidence warrant
that detention is warranted, and that there are no conditions or combination of conditions that
will secure a defendant’s appearance in court. In seeking to carry this burden, the government
relies on the presumption of detention in 18 U.S.C. § 3142(e)(3)(E), and argues that Ms.
Maxwell poses a flight risk because she supposedly lacks ties to the United States; is a citizen of
the United Kingdom and France, as well as a citizen of the United States, and has passports for
each country; has traveled internationally in the past; and has financial means. And echoing
recent media stories, the government speculates that Ms. Maxwell was “hiding” from law
enforcement during the pendency of the investigation, even though she has been in regular
contact with the government, through counsel, since Epstein’s arrest. Finally, the government
argues that the nature and circumstances of the offense and the weight of the evidence warrant
2
DOJ-OGR-00000962
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