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508 KB
Extraction Summary
5
People
2
Organizations
3
Locations
7
Events
3
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
508 KB
Summary
This legal document, filed on behalf of Ghislaine Maxwell, argues that she was not a flight risk prior to her arrest. It asserts that she intentionally moved to New Hampshire to be within driving distance of New York prosecutors and that her legal counsel was in regular, documented contact with the government for months. The filing aims to counter the government's portrayal of her as a fugitive by demonstrating her intent to remain in the U.S. and face any potential charges.
People (5)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
The subject of the legal filing, arguing she was not a flight risk.
|
| Ghislaine | Defendant |
First name of Ms. Maxwell, mentioned in a quote from her spouse's letter.
|
| Ms. Maxwell’s Counsel | Defense counsel |
Mentioned as being in regular contact with the government on behalf of Ms. Maxwell.
|
| Ms. Maxwell's spouse | Spouse of the defendant |
Mentioned as the author of a letter supporting Ms. Maxwell's intent to stay in the US.
|
| Epstein |
His arrest is mentioned as the starting point for communications between Ms. Maxwell's counsel and the government.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| The Government | government agency |
Refers to the U.S. government prosecutors, who argued Ms. Maxwell was a flight risk and were in contact with her coun...
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| Southern District of New York | government agency |
Mentioned as the prosecuting body, whose alleged failure to provide notice of arrest is described as 'uncharacteristic'.
|
Timeline (7 events)
2019-07
Defense counsel had an in-person meeting with the government.
2019-08
Defense counsel had an in-person meeting with the government.
2019-09
Defense counsel had an in-person meeting with the government.
2019-10
Defense counsel had an in-person meeting with the government.
2020-01
Defense counsel had an in-person meeting with the government.
2020-03
Defense counsel had an in-person meeting with the government.
Locations (3)
| Location | Context |
|---|---|
|
Location of the prosecutors; Ms. Maxwell is said to have moved to be within driving distance of them.
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Ms. Maxwell was 'adamant to not only stay in the United States'.
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Location where Ms. Maxwell moved into a house in December 2019.
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Relationships (3)
The document states that 'Ms. Maxwell, through her counsel, was also in regular contact with the government'.
The document refers to 'her spouse’s letter' which was submitted as evidence on her behalf.
The document details extensive contact (emails, phone calls, meetings) between the defense counsel and the government from July 2019 to March 2020.
Key Quotes (3)
"[Ghislaine] was adamant to not only stay in the United States to fight the smears against her, but to be within driving distance of New York."Source
— Ms. Maxwell's spouse
(Quoted from a letter (Ex. A) written by Ms. Maxwell's spouse to argue she did not intend to flee.)
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Quote #1
"[S]he was finally able to locate a place where she could not be moving around constantly and collect herself to fight for her life and to clear her name."Source
— Unknown (from Exhibit B)
(Quoted from an exhibit (Ex. B) to explain why Ms. Maxwell settled in New Hampshire.)
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Quote #2
"changing locations on multiple occasions"Source
— The Government
(A phrase attributed to the government's argument at a bail hearing, which this document seeks to rebut.)
DOJ-OGR-00001124.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,012 characters)
Case 20-cr-00330-AJN Document 202 Filed 02/04/20 Page 28 of 45
2. Ms. Maxwell’s Counsel Was in Regular Contact with the Government Prior to Her Arrest
At no time, however, did Ms. Maxwell intend to flee or hide from the government, as the government argued at the last bail hearing. In fact, her intent was exactly the opposite. As her spouse’s letter makes clear, after spending a few months away [REDACTED], Ms. Maxwell moved [REDACTED] so that she could [REDACTED] be within driving distance of the prosecutors in New York in case they wished to speak to her. (Ex. A ¶ 12) (“[Ghislaine] was adamant to not only stay in the United States to fight the smears against her, but to be within driving distance of New York.”). Contrary to the impression given by the government, Ms. Maxwell was not “changing locations on multiple occasions” as if she were a fugitive from justice. (Tr. 87). After Ms. Maxwell moved into the house in New Hampshire in December 2019, she remained there continuously for approximately seven months until her arrest. (See Ex. B) (“[S]he was finally able to locate a place where she could not be moving around constantly and collect herself to fight for her life and to clear her name.”).
Ms. Maxwell, through her counsel, was also in regular contact with the government from the moment of Epstein’s arrest up the time of her own arrest, as would be customary in such situations. Defense counsel corresponded by email, spoke on the phone, or had in-person meetings with government in July, August, September, and October 2019, and also in January and March 2020. The timeline attached to this submission illustrates the extent of these contacts. (Ex. R). Defense counsel also requested an opportunity to be heard in the event that the government was considering any charging decisions against Ms. Maxwell. We were never given that opportunity, which is uncharacteristic for the Southern District of New York, nor were we given any notice of her impending arrest.
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