DOJ-OGR-00001604.jpg
782 KB
Extraction Summary
5
People
4
Organizations
4
Locations
1
Events
1
Relationships
5
Quotes
Document Information
Type:
Legal filing (defense memorandum in support of bail application)
File Size:
782 KB
Summary
This document is page 24 of a legal filing (Document 18) from July 10, 2020, arguing for Ghislaine Maxwell's release on bail due to COVID-19 risks and the adequacy of the proposed bail package. The defense proposes a $5 million bond co-signed by six individuals (siblings, relatives, friends) and secured by $3.75 million in UK property, along with home detention, GPS monitoring, and travel restrictions to NY districts. A footnote cites *United States v. Boustani* to argue that private security guards are appropriate given Maxwell's circumstances.
People (5)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the bail application; defense argues for her release based on proposed bail package and COVID-19 concerns.
|
| Maxwell's siblings | Co-signers |
Part of the six co-signers supporting the bond.
|
| Maxwell's relatives | Co-signers |
Part of the six co-signers supporting the bond.
|
| Maxwell's friends | Co-signers |
Part of the six co-signers supporting the bond.
|
| Boustani | Legal Precedent |
Defendant in United States v. Boustani, cited in footnote 16 regarding use of private security guards for bail.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| The Court |
Addressed in the filing (likely SDNY based on case number suffix AJN).
|
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| Pretrial Services |
Proposed entity to whom security guards could report.
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| Second Circuit |
Court of Appeals cited in footnote 16.
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| DOJ |
Department of Justice (referenced in footer stamp DOJ-OGR).
|
Timeline (1 events)
2020-07-10
Filing of Document 18 in Case 1:20-cr-00330-AJN
Southern District of New York
Ghislaine Maxwell's Defense Team
Locations (4)
| Location | Context |
|---|---|
|
Residence of many co-signers; location of Maxwell's ties mentioned in footnote.
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|
|
Location of real property used to secure the bond.
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Proposed area of restricted travel.
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Proposed area of restricted travel.
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Relationships (1)
The package includes six co-signers... all of whom continue to support her
Key Quotes (5)
"The Proposed Bail Package Is More Than Adequate to Secure Ms. Maxwell’s Presence"Source
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Quote #1
"Each of them has voluntarily agreed to assume responsibility for an extremely large bond amount of $5 million"Source
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Quote #2
"The bond is also to be secured by real property in the United Kingdom worth roughly $3.75 million."Source
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Quote #3
"Ms. Maxwell, for personal reasons, will continue to need security guards to protect her upon release."Source
DOJ-OGR-00001604.jpg
Quote #4
"support her despite the unrelenting media attacks that Ms. Maxwell and they, themselves, have suffered"Source
DOJ-OGR-00001604.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (2,488 characters)
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 24 of 26
3. The Proposed Bail Package Is More Than
Adequate to Secure Ms. Maxwell’s Presence
Adequate to Secure Ms. Maxwell’s Presence
For the reasons stated above, the Court should release Ms. Maxwell because the
circumstances created by the COVID-19 pandemic will greatly increase her personal risk
and prevent her from meaningfully participating in her defense, and because the government
has not carried its burden under 18 U.S.C. § 3142. We respectfully submit that the proposed
bail package represents the “least restrictive” set of conditions that will reasonably ensure Ms.
Maxwell’s presence in court. 18 U.S.C. § 3142 (c)(1)(B).
circumstances created by the COVID-19 pandemic will greatly increase her personal risk
and prevent her from meaningfully participating in her defense, and because the government
has not carried its burden under 18 U.S.C. § 3142. We respectfully submit that the proposed
bail package represents the “least restrictive” set of conditions that will reasonably ensure Ms.
Maxwell’s presence in court. 18 U.S.C. § 3142 (c)(1)(B).
The package includes six co-signers—Ms. Maxwell’s siblings, relatives and
friends—many of whom reside in the United States, and all of whom continue to support her
despite the unrelenting media attacks that Ms. Maxwell and they, themselves, have suffered
as a result of this case. Each of them has voluntarily agreed to assume responsibility for an
extremely large bond amount of $5 million, in order to secure her appearance. The bond is
also to be secured by real property in the United Kingdom worth roughly $3.75 million.
The package also includes stringent travel and physical restrictions, including surrendering
all passports and no new travel applications, travel restricted to the Southern and Eastern
Districts of New York, and home detention with electronic GPS monitoring. Ms. Maxwell,
for personal reasons, will continue to need security guards to protect her upon release.
Under the circumstances, if the Court requires it, the security guards could report to Pretrial
Services.16
friends—many of whom reside in the United States, and all of whom continue to support her
despite the unrelenting media attacks that Ms. Maxwell and they, themselves, have suffered
as a result of this case. Each of them has voluntarily agreed to assume responsibility for an
extremely large bond amount of $5 million, in order to secure her appearance. The bond is
also to be secured by real property in the United Kingdom worth roughly $3.75 million.
The package also includes stringent travel and physical restrictions, including surrendering
all passports and no new travel applications, travel restricted to the Southern and Eastern
Districts of New York, and home detention with electronic GPS monitoring. Ms. Maxwell,
for personal reasons, will continue to need security guards to protect her upon release.
Under the circumstances, if the Court requires it, the security guards could report to Pretrial
Services.16
16 In United States v. Boustani, 932 F.3d 79 (2d Cir. 2019), the Second Circuit curtailed the circumstances under
which a court can grant pretrial release to a defendant on the condition that the defendant pays for private armed
security guards. Boustani, nevertheless, held that a defendant may be released on such a condition if the defendant
“is deemed to be a flight risk primarily because of his wealth. In other words, a defendant may be released on such a
condition only where, but for his wealth, he would not have been detained.” Id. (emphasis in original). We submit
that a similarly situated defendant who, like Ms. Maxwell, had no prior criminal record, significant ties to the United
States, and a demonstrated lack of intent to flee the country, as well as numerous, supportive co-signers, but who did
which a court can grant pretrial release to a defendant on the condition that the defendant pays for private armed
security guards. Boustani, nevertheless, held that a defendant may be released on such a condition if the defendant
“is deemed to be a flight risk primarily because of his wealth. In other words, a defendant may be released on such a
condition only where, but for his wealth, he would not have been detained.” Id. (emphasis in original). We submit
that a similarly situated defendant who, like Ms. Maxwell, had no prior criminal record, significant ties to the United
States, and a demonstrated lack of intent to flee the country, as well as numerous, supportive co-signers, but who did
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DOJ-OGR-00001604
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