DOJ-OGR-00019880.jpg
737 KB
Extraction Summary
3
People
2
Organizations
3
Locations
3
Events
2
Relationships
2
Quotes
Document Information
Type:
Court filing / legal memorandum (defense motion regarding bail/detention)
File Size:
737 KB
Summary
This is page 2 of a legal memorandum filed by the defense in the case of United States v. Ghislaine Maxwell. It outlines her background, emphasizing her ties to the US, family support, and citizenship status to argue against flight risk. It counters the government's position that she was 'hiding' and argues that detention is not warranted.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
58-year-old naturalized US citizen, also citizen of France and UK. Subject of detention hearing.
|
| Jeffrey Epstein | Deceased/Co-conspirator |
Mentioned regarding his July 2019 indictment and arrest.
|
| Maxwell's Siblings | Family |
Six siblings, nephews, and nieces who support her. Two sisters specifically noted as residing in the US.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Oxford University |
University from which Ms. Maxwell graduated.
|
|
| The Government (US DOJ) |
Prosecution arguing for detention based on flight risk.
|
Timeline (3 events)
Locations (3)
| Location | Context |
|---|---|
|
Maxwell's residence since 1991.
|
|
|
Maxwell's birthplace and country of citizenship.
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|
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Country of education/childhood and citizenship.
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Relationships (2)
Document mentions the 'aftermath of the July 2019 indictment of Epstein'.
Maintained extremely close relationships; they stood by her.
Key Quotes (2)
"Ms. Maxwell’s family and friends have remained committed to her because they do not believe the allegations against her, which do not match the person they have known for decades."Source
DOJ-OGR-00019880.jpg
Quote #1
"the government speculates that Ms. Maxwell was “hiding” from law enforcement during the pendency of the investigation, even though she has been in regular contact with the government, through counsel, since Epstein’s arrest."Source
DOJ-OGR-00019880.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (2,196 characters)
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 2 of 20
Case 1:20-cr-00330-AJN Document 39-2 Filed 04/01/21 Page 2 of 20
Case 1:20-cr-00330-AJN Document 39-2 Filed 04/01/21 Page 2 of 20
Background. Ms. Maxwell, 58, is a naturalized U.S. citizen who has resided in the
United States since 1991. She is also a citizen of France, where she was born, and of the United
Kingdom, where she was educated and spent her childhood and formative years. Ms. Maxwell
graduated from Oxford University. She moved to the United States in 1991, and has lived in this
country ever since that time. Ms. Maxwell has maintained extremely close relationships with her
six siblings and her nephews and nieces. They all stood by her in the aftermath of the July 2019
indictment of Epstein and continue to stand by her now. She is especially close to two of her
sisters and their children, all of whom reside in the United States. Ms. Maxwell also has
numerous friends in the United States who themselves have children, and she is a godmother to
many of them. Ms. Maxwell’s family and friends have remained committed to her because they
do not believe the allegations against her, which do not match the person they have known for
decades.
United States since 1991. She is also a citizen of France, where she was born, and of the United
Kingdom, where she was educated and spent her childhood and formative years. Ms. Maxwell
graduated from Oxford University. She moved to the United States in 1991, and has lived in this
country ever since that time. Ms. Maxwell has maintained extremely close relationships with her
six siblings and her nephews and nieces. They all stood by her in the aftermath of the July 2019
indictment of Epstein and continue to stand by her now. She is especially close to two of her
sisters and their children, all of whom reside in the United States. Ms. Maxwell also has
numerous friends in the United States who themselves have children, and she is a godmother to
many of them. Ms. Maxwell’s family and friends have remained committed to her because they
do not believe the allegations against her, which do not match the person they have known for
decades.
The Government’s Position. The government has the burden of persuasion in showing
that detention is warranted, and that there are no conditions or combination of conditions that
will secure a defendant’s appearance in court. In seeking to carry this burden, the government
relies on the presumption of detention in 18 U.S.C. § 3142(e)(3)(E), and argues that Ms.
Maxwell poses a flight risk because she supposedly lacks ties to the United States; is a citizen of
the United Kingdom and France, as well as a citizen of the United States, and has passports for
each country; has traveled internationally in the past; and has financial means. And echoing
recent media stories, the government speculates that Ms. Maxwell was “hiding” from law
enforcement during the pendency of the investigation, even though she has been in regular
contact with the government, through counsel, since Epstein’s arrest. Finally, the government
argues that the nature and circumstances of the offense and the weight of the evidence warrant
that detention is warranted, and that there are no conditions or combination of conditions that
will secure a defendant’s appearance in court. In seeking to carry this burden, the government
relies on the presumption of detention in 18 U.S.C. § 3142(e)(3)(E), and argues that Ms.
Maxwell poses a flight risk because she supposedly lacks ties to the United States; is a citizen of
the United Kingdom and France, as well as a citizen of the United States, and has passports for
each country; has traveled internationally in the past; and has financial means. And echoing
recent media stories, the government speculates that Ms. Maxwell was “hiding” from law
enforcement during the pendency of the investigation, even though she has been in regular
contact with the government, through counsel, since Epstein’s arrest. Finally, the government
argues that the nature and circumstances of the offense and the weight of the evidence warrant
2
DOJ-OGR-00019880
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