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Extraction Summary
3
People
2
Organizations
1
Locations
2
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal filing (government opposition to bail motion)
File Size:
713 KB
Summary
This document is page 16 of a legal filing (Government's opposition) filed on December 18, 2020, in the case United States v. Ghislaine Maxwell (1:20-cr-00330-AJN). The text argues against the defendant's 'Renewed Bail Application,' stating that the defense is reiterating arguments already rejected by the Court. The prosecution asserts the defendant remains a 'substantial actual risk of flight' and highlights the 'horrendous conduct' involving the sexual abuse of minors charged in the indictment.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant (Implied) |
Subject of the bail hearing and detention order (referred to as 'the defendant').
|
| Jeffrey Epstein | Associate |
Mentioned in relation to the defendant's behavior 'after Epstein's arrest'.
|
| The Court | Judicial Authority |
The entity being asked to reverse its prior decision regarding bail.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| United States District Court |
Implied by case number 1:20-cr-00330-AJN (S.D.N.Y).
|
|
| Department of Justice |
Indicated by footer DOJ-OGR.
|
Timeline (2 events)
Locations (1)
| Location | Context |
|---|---|
|
Mentioned regarding the defendant's ties to the country.
|
Relationships (1)
Document references defendant's behavior 'after Epstein's arrest'.
Key Quotes (3)
"The Renewed Bail Application largely reiterates the same claims regarding the defendant’s ties to the United States and her behavior after Epstein’s arrest that the Court already found unpersuasive."Source
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Quote #1
"Ultimately, nothing in the Renewed Bail Application alters the analysis that led this Court to conclude that the defendant “poses a substantial actual risk of flight,”"Source
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Quote #2
"The charges in the Indictment describe horrendous conduct involving the sexual abuse of multiple minor victims."Source
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Quote #3
Full Extracted Text
Complete text extracted from the document (2,045 characters)
Case 1:20-cr-00330-AJN Document 100 Filed 12/18/20 Page 16 of 36
reconsideration” by, for example, demonstrating “that the court overlooked information or
incorrectly applied the law,” or that failure to reconsider “would constitute manifest injustice.”
Petrov, 2015 WL 1102286 at *3.
incorrectly applied the law,” or that failure to reconsider “would constitute manifest injustice.”
Petrov, 2015 WL 1102286 at *3.
DISCUSSION
Having already raised numerous arguments in its briefing and oral argument at the initial
bail hearing in this case, the defense now asks this Court to reverse itself based on virtually the
same arguments it already rejected. The Renewed Bail Application largely reiterates the same
claims regarding the defendant’s ties to the United States and her behavior after Epstein’s arrest
that the Court already found unpersuasive. To the extent the Renewed Bail Application presents
new information, it consists primarily of financial data that was certainly known to the defendant
at the time of her initial bail application and that the Court already assumed could be made
available (and thus rejected as immaterial) when ordering detention. Ultimately, nothing in the
Renewed Bail Application alters the analysis that led this Court to conclude that the defendant
“poses a substantial actual risk of flight,” and that no combination of conditions could assure her
appearance. (Tr. 86). All three of the relevant Bail Reform Act factors still weigh heavily in favor
of detention, and the defense claims to the contrary do not warrant a revisiting of this Court’s well-
reasoned and thorough prior decision.
bail hearing in this case, the defense now asks this Court to reverse itself based on virtually the
same arguments it already rejected. The Renewed Bail Application largely reiterates the same
claims regarding the defendant’s ties to the United States and her behavior after Epstein’s arrest
that the Court already found unpersuasive. To the extent the Renewed Bail Application presents
new information, it consists primarily of financial data that was certainly known to the defendant
at the time of her initial bail application and that the Court already assumed could be made
available (and thus rejected as immaterial) when ordering detention. Ultimately, nothing in the
Renewed Bail Application alters the analysis that led this Court to conclude that the defendant
“poses a substantial actual risk of flight,” and that no combination of conditions could assure her
appearance. (Tr. 86). All three of the relevant Bail Reform Act factors still weigh heavily in favor
of detention, and the defense claims to the contrary do not warrant a revisiting of this Court’s well-
reasoned and thorough prior decision.
A. The Nature and Circumstances of the Offense
The first Bail Reform Act factor indisputably weighs in favor of detention in this case. The
egregious conduct charged in the Indictment gives rise to a statutory presumption of detention, and
the Renewed Bail Motion makes no effort to challenge this Court’s prior conclusion that the nature
and circumstances of the offense support detention. The charges in the Indictment describe
horrendous conduct involving the sexual abuse of multiple minor victims. If convicted, the
egregious conduct charged in the Indictment gives rise to a statutory presumption of detention, and
the Renewed Bail Motion makes no effort to challenge this Court’s prior conclusion that the nature
and circumstances of the offense support detention. The charges in the Indictment describe
horrendous conduct involving the sexual abuse of multiple minor victims. If convicted, the
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DOJ-OGR-00001153
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