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765 KB
Extraction Summary
8
People
2
Organizations
4
Locations
2
Events
1
Relationships
5
Quotes
Document Information
Type:
Legal filing (court motion/memorandum)
File Size:
765 KB
Summary
This document is page 20 of a legal filing (Document 18) dated July 10, 2020, in the case United States v. Ghislaine Maxwell. The text argues against the government's assertion that Maxwell is a flight risk, citing her isolation as a protective measure rather than an attempt to flee, and noting that wealth and foreign citizenship alone are insufficient grounds for detention without proof of 'inclination' to flee. It also argues that COVID-19 travel restrictions make flight unlikely and mentions in a footnote that individuals in the media (specifically in the UK) are falsely claiming to have ties to her.
People (8)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the bail hearing; described as a woman of means with foreign citizenship.
|
| Sabhnani | Legal Precedent |
Cited in case law regarding flight risk.
|
| Hung | Legal Precedent |
Cited in Hung v. United States regarding requirements to prove inclination to flee.
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| Hansen | Legal Precedent |
Cited in United States v. Hansen.
|
| Hanson | Legal Precedent |
Cited in United States v. Hanson.
|
| Bodmer | Legal Precedent |
Cited in United States v. Bodmer.
|
| Karni | Legal Precedent |
Cited in United States v. Karni.
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| Kashoggi | Legal Precedent |
Cited in United States v. Kashoggi.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| United States District Court |
Implied by case number format and citations (S.D.N.Y.).
|
|
| DOJ |
Department of Justice (referenced in Bates stamp DOJ-OGR-00001600).
|
Timeline (2 events)
2020-07-10
Locations (4)
| Location | Context |
|---|---|
|
Jurisdiction of the court; location from which Maxwell might flee.
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|
|
Mentioned in footnote where a person claiming ties to Maxwell gave television interviews.
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|
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Southern District of New York (legal jurisdiction cited).
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|
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District Court for the District of Columbia (legal jurisdiction cited).
|
Relationships (1)
Footnote 12 mentions people claiming to speak for her or have direct communications who have 'no ties to Ms. Maxwell whatsoever'.
Key Quotes (5)
"Ms. Maxwell therefore did what any responsible person would do – she separated herself from everyone she cares about and removed herself from the public eye in order to keep herself and her friends out of harm’s way."Source
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Quote #1
"Ms. Maxwell is a woman of means who has foreign citizenship and has traveled internationally in the past"Source
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Quote #2
"government must show more than 'opportunities for flight,' and instead must establish an 'inclination on the part of [the defendant] to flee'"Source
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Quote #3
"the ongoing travel restrictions caused by the COVID-19 pandemic would pose a significant hurdle to Ms. Maxwell’s ability to flee the United States"Source
DOJ-OGR-00001600.jpg
Quote #4
"The media spotlight has also drawn out people who claim to speak for Ms. Maxwell... but who, in fact, have no ties to Ms. Maxwell whatsoever."Source
DOJ-OGR-00001600.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (2,293 characters)
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 20 of 26
suffered severe professional and reputational damage simply by being associated with her. Ms.
Maxwell therefore did what any responsible person would do – she separated herself from
everyone she cares about and removed herself from the public eye in order to keep herself and
her friends out of harm’s way. 12
Maxwell therefore did what any responsible person would do – she separated herself from
everyone she cares about and removed herself from the public eye in order to keep herself and
her friends out of harm’s way. 12
Lacking any evidence required under the governing standard that Ms. Maxwell
presents an “actual risk of flight,” Sabhnani, 493 F.3d at 75, the government’s flight risk
argument is reduced to the following: Ms. Maxwell is a woman of means who has foreign
citizenship and has traveled internationally in the past, and who now faces serious charges.
But if that were sufficient, then virtually every defendant with a foreign passport and any
meaningful amount of funds would need to be detained as a flight risk. See Hung v. United
States 439 U.S. 1326, 1329 (1978) (to detain based on risk of flight, government must show
more than “opportunities for flight,” and instead must establish an “inclination on the part of
[the defendant] to flee”). That is not what the Bail Reform Act requires. Indeed, courts in
this Circuit and elsewhere commonly find that bail conditions can adequately address risk of
flight, even where individuals have foreign citizenship and passports or otherwise substantial
foreign connections, and financial means. See, e.g., Sabhnani, 493 F.3d at 66; United States v.
Hansen, 108 F. App’x 331 (6th Cir. 2004); United States v. Hanson, 613 F. Supp. 2d 85 (D.D.C.
2009); United States v. Bodmer, No. 03-cr-947(SAS), 2004 WL 169790, at *2-3 (S.D.N.Y.
Jan. 28. 2004); United States v. Karni, 298 F. Supp. 2d 129 (D.D.C. 2004); United States v.
Kashoggi, 717 F. Supp. 1048, 1050-52 (S.D.N.Y. 1989).
presents an “actual risk of flight,” Sabhnani, 493 F.3d at 75, the government’s flight risk
argument is reduced to the following: Ms. Maxwell is a woman of means who has foreign
citizenship and has traveled internationally in the past, and who now faces serious charges.
But if that were sufficient, then virtually every defendant with a foreign passport and any
meaningful amount of funds would need to be detained as a flight risk. See Hung v. United
States 439 U.S. 1326, 1329 (1978) (to detain based on risk of flight, government must show
more than “opportunities for flight,” and instead must establish an “inclination on the part of
[the defendant] to flee”). That is not what the Bail Reform Act requires. Indeed, courts in
this Circuit and elsewhere commonly find that bail conditions can adequately address risk of
flight, even where individuals have foreign citizenship and passports or otherwise substantial
foreign connections, and financial means. See, e.g., Sabhnani, 493 F.3d at 66; United States v.
Hansen, 108 F. App’x 331 (6th Cir. 2004); United States v. Hanson, 613 F. Supp. 2d 85 (D.D.C.
2009); United States v. Bodmer, No. 03-cr-947(SAS), 2004 WL 169790, at *2-3 (S.D.N.Y.
Jan. 28. 2004); United States v. Karni, 298 F. Supp. 2d 129 (D.D.C. 2004); United States v.
Kashoggi, 717 F. Supp. 1048, 1050-52 (S.D.N.Y. 1989).
Finally, the ongoing travel restrictions caused by the COVID-19 pandemic would
pose a significant hurdle to Ms. Maxwell’s ability to flee the United States, particularly to
pose a significant hurdle to Ms. Maxwell’s ability to flee the United States, particularly to
12 The media spotlight has also drawn out people who claim to speak for Ms. Maxwell, and even purport to have had
direct communications with her, but who, in fact, have no ties to Ms. Maxwell whatsoever. One such person has
even given numerous television interviews on news shows in the United Kingdom.
direct communications with her, but who, in fact, have no ties to Ms. Maxwell whatsoever. One such person has
even given numerous television interviews on news shows in the United Kingdom.
16
DOJ-OGR-00001600
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