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864 KB

Extraction Summary

5
People
4
Organizations
2
Locations
4
Events
2
Relationships
2
Quotes

Document Information

Type: Legal document
File Size: 864 KB
Summary

This legal document, filed on behalf of Ghislaine Maxwell, argues that she is not a flight risk and should be granted release. It refutes the government's claim of her 'frequent international travel' by emphasizing that she has remained in the United States since Jeffrey Epstein's arrest in July 2019 and subsequent death in August 2019. The filing contends that her decision to stay in the U.S. despite intense media scrutiny and public calls for her prosecution demonstrates she has no intention of fleeing.

People (5)

Name Role Context
Epstein
Mentioned in relation to his arrest, death, and abuse cases, and his connection to Ms. Maxwell.
Ms. Maxwell
The subject of the document, arguing she is not a flight risk because she remained in the US after Epstein's arrest a...
Ghislaine Maxwell British socialite 'fixer'
Full name mentioned in footnotes citing news articles about her connection to Jeffrey Epstein.
Friedman
Mentioned in a case citation, "United States v. Friedman".
Jeffrey Epstein
Full name mentioned in footnotes citing news articles.

Organizations (4)

Name Type Context
Southern District of New York government agency
The jurisdiction where Epstein-related cases were handled and where prosecutors were contacted by Ms. Maxwell's counsel.
Daily Mail company
News organization cited in a footnote.
The Guardian company
News organization cited in a footnote.
NBC News company
News organization cited in a footnote.

Timeline (4 events)

2019-07-06
Arrest of Epstein. The document states July 7, 2019 was 'the day after Epstein's arrest'.
2019-07-07
Ms. Maxwell reached out to prosecutors in the Southern District of New York through her counsel.
Southern District of New York
Ms. Maxwell counsel prosecutors in the Southern District of New York
2019-08
Death of Epstein.
circa 2020-07
Ms. Maxwell was arrested after staying in the United States for almost an entire year.
United States

Locations (2)

Location Context
Location of the prosecutors and cases related to Epstein.
The country where Ms. Maxwell remained after Epstein's arrest and death.

Relationships (2)

Ms. Maxwell association Epstein
The document discusses Ms. Maxwell's actions in the context of Epstein's arrest and death. Footnotes refer to her as his 'fixer' and someone accused of helping him 'groom girls'.
Ms. Maxwell professional counsel
The document states that Ms. Maxwell reached out to prosecutors 'through counsel'.

Key Quotes (2)

"frequent international travel"
Source
— The government (An assertion made by the government about Ms. Maxwell's travel in the last three years, which this document aims to rebut.)
DOJ-OGR-00000973.jpg
Quote #1
"she has not left the country even once since Epstein’s arrest"
Source
— Author of the document (Ms. Maxwell's counsel) (The critical point made to counter the government's assertion and argue that Ms. Maxwell is not a flight risk.)
DOJ-OGR-00000973.jpg
Quote #2

Full Extracted Text

Complete text extracted from the document (2,586 characters)

Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 17 of 260
cases related to Epstein in the Southern District of New York and has sat for depositions in
those cases. Similarly, throughout the course of the criminal investigation of this case,
which has been publicly reported on for nearly a year, Ms. Maxwell has remained in the
United States. Indeed, on July 7, 2019, the day after Epstein’s arrest, Ms. Maxwell reached
out to the prosecutors in the Southern District of New York, through counsel, and
maintained regular contact with them right up to the point of her arrest.
The government’s broad assertion that Ms. Maxwell has engaged in “frequent
international travel” in the last three years (Gov. Mem. at 6) obscures the critical point: she
has not left the country even once since Epstein’s arrest. Ms. Maxwell’s decision to remain
in the United States after Epstein’s arrest and subsequent death in August 2019 is
particularly significant because any incentive she may have had to flee would have been
even more acute at that time. Within days of Epstein’s death, a steady stream of press
articles began turning the public’s attention to Ms. Maxwell—wrongly substituting her for
Epstein—and speculating that she had become the prime target of the government’s
investigation.⁹ Adding even more fuel to this fire, several of the women claiming to be
victims of Epstein’s abuse began publicly calling for her immediate arrest and prosecution.
Despite the increasing risk of being criminally charged, and the media firestorm that was
redirected toward her after Epstein’s death, and despite having ample opportunity to leave
the country, Ms. Maxwell stayed in the United States for almost an entire year until she was
arrested. These actions weigh heavily in favor of release. See United States v. Friedman,
⁹ See, e.g., Spotlight turns on Jeffrey Epstein’s British socialite ‘fixer’ Ghislaine Maxwell after his suicide – but will
she be prosecuted?, Daily Mail (Aug. 10, 2019), https://www.dailymail.co.uk/news/article-7344765/Spotlight-turns-
Jeffrey-Epsteins-fixer-Ghislaine-Maxwell-suicide.html; Ghislaine Maxwell: the woman accused of helping Jeffrey
Epstein groom girls, The Guardian (Aug. 12, 2019), https://www.theguardian.com/us-news/2019/aug/12/ghislaine-
maxwell-woman-accused-jeffrey-epstein-groom-girls; British socialite Ghislaine Maxwell in spotlight after
Epstein’s apparent suicide, NBC News (Aug. 12, 2019), https://www.nbcnews.com/news/us-news/british-socialite-
ghislaine-maxwell-spotlight-after-epsteins-apparent-suicide-n1041111.
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