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768 KB
Extraction Summary
5
People
5
Organizations
3
Locations
4
Events
1
Relationships
3
Quotes
Document Information
Type:
Court filing (government memorandum)
File Size:
768 KB
Summary
This document is page 15 of a Government memorandum filed on July 13, 2020, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The prosecution argues against granting bail, citing that the MDC is adequately handling COVID-19 risks and referencing legal precedents where bail was denied despite the pandemic. A footnote emphasizes the Government's position that the defendant has the financial means to flee the country and that pandemic travel restrictions would not prevent her flight.
People (5)
| Name | Role | Context |
|---|---|---|
| Defendant | Defendant |
Subject of the bail hearing; referred to as 'she'. Context of Case 1:20-cr-00330-AJN identifies this as Ghislaine Max...
|
| Swain, J. | Judge |
Cited in United States v. Hanes-Calugaru.
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| Hellerstein, J. | Judge |
Cited in United States v. Curry.
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| Hanes-Calugaru | Defendant (Case Law) |
Defendant in cited case denied bail despite health risks.
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| Curry | Defendant (Case Law) |
Defendant in cited case denied bail.
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| MDC |
Metropolitan Detention Center; facility where defendant is held.
|
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| BOP |
Bureau of Prisons; agency managing the MDC.
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| District Court |
Eastern District of New York and Southern District of New York.
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| CDC |
Centers for Disease Control; provided guidance on high-risk lists.
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| The Government |
Prosecution; arguing against bail.
|
Timeline (4 events)
2020-05-04
Locations (3)
| Location | Context |
|---|---|
|
Detention center where the defendant is held.
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Location of civil lawsuit Chunn v. Edge.
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|
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Southern District of New York; court jurisdiction.
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Relationships (1)
Government submits arguments against defendant's release.
Key Quotes (3)
"MDC officials have recognized COVID-19 as a serious threat and responded aggressively."Source
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Quote #1
"The Government submits that the defendant has the means and resources to find her way out of the country, and a short quarantine period abroad would be a small price to pay to avoid years in prison."Source
DOJ-OGR-00001625.jpg
Quote #2
"she cannot claim any greater need for bail than the many inmates awaiting trial there."Source
DOJ-OGR-00001625.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,342 characters)
Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 15 of 19
than any other inmate at the MDC, and thus she cannot claim any greater need for bail than the
many inmates awaiting trial there.³
many inmates awaiting trial there.³
The virus, of course, presents new and complex challenges for protecting inmates’ health,
but the BOP generally, and the MDC specifically, are prepared to handle the risks presented by
COVID-19 and other health issues. The MDC’s response to the pandemic was the subject of
extensive evidentiary hearings in the context of a civil lawsuit in the Eastern District of New York.
See Chunn v. Edge, No. 20 Cr. 1590, 2020 WL 3055669 (E.D.N.Y. June 9, 2020). In Chunn, the
District Court conducted extensive fact gathering about the conditions at the MDC before
concluding that “MDC officials have recognized COVID-19 as a serious threat and responded
aggressively.” Id. at *1; see also id. at 25 (“The MDC’s response to COVID-19 has been
aggressive and has included, among other steps, massively restricting movement within the
facility, enhancing sanitation protocols, and creating quarantine and isolation units. And the data—
though limited—suggests that these measures have been quite effective in containing COVID-19
thus far.”).
but the BOP generally, and the MDC specifically, are prepared to handle the risks presented by
COVID-19 and other health issues. The MDC’s response to the pandemic was the subject of
extensive evidentiary hearings in the context of a civil lawsuit in the Eastern District of New York.
See Chunn v. Edge, No. 20 Cr. 1590, 2020 WL 3055669 (E.D.N.Y. June 9, 2020). In Chunn, the
District Court conducted extensive fact gathering about the conditions at the MDC before
concluding that “MDC officials have recognized COVID-19 as a serious threat and responded
aggressively.” Id. at *1; see also id. at 25 (“The MDC’s response to COVID-19 has been
aggressive and has included, among other steps, massively restricting movement within the
facility, enhancing sanitation protocols, and creating quarantine and isolation units. And the data—
though limited—suggests that these measures have been quite effective in containing COVID-19
thus far.”).
Numerous judges in this District have rejected applications for release based on assertions
about the hypothetical risks of COVID-19, including multiple cases involving defendants who,
unlike this defendant, suffer from underlying health conditions. See, e.g., United States v. Hanes-
Calugaru, No. 19 Cr. 651, ECF No. 257 (S.D.N.Y. May 4, 2020) (Swain, J.) (denying pre-trial
bail application by defendant who was on MDC’s initial high-risk list but subsequently removed
following new CDC guidance (see ECF Nos. 239, 242, 257)); United States v. Curry, 19 Cr. 742,
ECF No. 37 (S.D.N.Y. Apr. 30, 2020) (Hellerstein, J.) (denying pre-trial bail application by
about the hypothetical risks of COVID-19, including multiple cases involving defendants who,
unlike this defendant, suffer from underlying health conditions. See, e.g., United States v. Hanes-
Calugaru, No. 19 Cr. 651, ECF No. 257 (S.D.N.Y. May 4, 2020) (Swain, J.) (denying pre-trial
bail application by defendant who was on MDC’s initial high-risk list but subsequently removed
following new CDC guidance (see ECF Nos. 239, 242, 257)); United States v. Curry, 19 Cr. 742,
ECF No. 37 (S.D.N.Y. Apr. 30, 2020) (Hellerstein, J.) (denying pre-trial bail application by
__________________________________________________________________
³ The defendant also argues that the circumstances of the pandemic would pose a “significant
hurdle” to the defendant’s ability to flee. Opposition Memorandum at 16. The Government
submits that the defendant has the means and resources to find her way out of the country, and a
short quarantine period abroad would be a small price to pay to avoid years in prison.
³ The defendant also argues that the circumstances of the pandemic would pose a “significant
hurdle” to the defendant’s ability to flee. Opposition Memorandum at 16. The Government
submits that the defendant has the means and resources to find her way out of the country, and a
short quarantine period abroad would be a small price to pay to avoid years in prison.
14
DOJ-OGR-00001625
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