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743 KB
Extraction Summary
5
People
3
Organizations
2
Locations
3
Events
2
Relationships
5
Quotes
Document Information
Type:
Court filing / legal memorandum (government opposition to bail)
File Size:
743 KB
Summary
This document is a page from a Government filing (likely opposing bail) in the case against Ghislaine Maxwell (Case 1:20-cr-00330). It argues that the defendant is a flight risk, noting that she actively hid from law enforcement and the media, and that her lawyers refused to disclose her location to the Government despite ongoing communications in 2019 and 2020. The text details the circumstances of her arrest, stating that she ignored FBI directives and ran away from clearly identified agents to hide in an inner room.
People (5)
| Name | Role | Context |
|---|---|---|
| The Defendant | Accused |
Refers to Ghislaine Maxwell (based on case number 1:20-cr-00330-AJN context); described as evading detection, hiding ...
|
| Defense Counsel | Legal Representatives |
Lawyers representing the defendant; communicated with the Government but refused to disclose defendant's location.
|
| The Government | Prosecution |
Refers to the DOJ/Prosecutors arguing for detention.
|
| FBI Agents | Law Enforcement |
Attempted to serve subpoena; eventually arrested defendant; wore clearly identifying clothing during raid.
|
| Private Security Team | Security |
Defendant's security personnel who provided an affidavit regarding the arrest/security protocols.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| FBI |
Federal Bureau of Investigation; attempted service and executed arrest.
|
|
| The Court |
Judicial body presiding over the case (Judge Alison J. Nathan, implied by AJN in case number).
|
|
| Media / Media Outlets |
Entities searching for the defendant.
|
Timeline (3 events)
2020-07-14
Unknown (Date of Arrest)
FBI located and arrested defendant; defendant ran away from agents despite them being clearly identified.
Defendant's property
Defendant
FBI Agents
Locations (2)
| Location | Context |
|---|---|
|
Location where the arrest took place.
|
|
|
Specific location within the property designated as a security retreat protocol.
|
Relationships (2)
Communicated on multiple occasions between July and October of 2019
Defendant ran away from the arresting agents.
Key Quotes (5)
"It is undisputed that defense counsel, even while in contact with the Government, never disclosed the defendant’s location or offered her surrender if she were to be charged."Source
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Quote #1
"At no point did defense counsel disclose the defendant’s location, offer to surrender the defendant, or offer to bring the defendant in to be interviewed."Source
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Quote #2
"Moreover it is undisputed that when the FBI located the defendant, she ignored their directives and ran away from the arresting agents."Source
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Quote #3
"The defense already informed the Court at the July 14, 2020 bail hearing that the defendant’s security protocol was to move to an inner room if her security was breached."Source
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Quote #4
"agents who entered the defendant’s property were wearing clothing that clearly identified them as FBI agents."Source
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Quote #5
Full Extracted Text
Complete text extracted from the document (2,191 characters)
Case 1:20-cr-00330-AJN Document 100 Filed 12/28/20 Page 24 of 36
the media even when a bounty was offered for her location and when numerous media outlets were
searching for her.
searching for her.
The charts, graphs, and affidavits proffered by the defense do not undercut the defendant’s
skill at evading detection, and do nothing more than restate the justification for those actions that
the defense already made at the prior hearing. (See Dkt. 18 at 14-16). That said, there is still
reason to believe that the defendant was hiding not just from the press, but also from law
enforcement. It is undisputed that defense counsel, even while in contact with the Government,
never disclosed the defendant’s location or offered her surrender if she were to be charged. (Tr.
53-54). The Court already inquired about defense counsel’s interactions with the Government in
the year leading up to the defendant’s arrest, and the Renewed Bail Application offers nothing new
on that score. (Id.). Defense counsel contacted the Government when the FBI attempted to serve
the defendant with a subpoena, but were unable to locate her, on July 7, 2019. Prior to her arrest,
the Government and defense counsel communicated on multiple occasions between July and
October of 2019, and communicated briefly on two additional occasions, most recently in March
of 2020. At no point did defense counsel disclose the defendant’s location, offer to surrender the
defendant, or offer to bring the defendant in to be interviewed.
skill at evading detection, and do nothing more than restate the justification for those actions that
the defense already made at the prior hearing. (See Dkt. 18 at 14-16). That said, there is still
reason to believe that the defendant was hiding not just from the press, but also from law
enforcement. It is undisputed that defense counsel, even while in contact with the Government,
never disclosed the defendant’s location or offered her surrender if she were to be charged. (Tr.
53-54). The Court already inquired about defense counsel’s interactions with the Government in
the year leading up to the defendant’s arrest, and the Renewed Bail Application offers nothing new
on that score. (Id.). Defense counsel contacted the Government when the FBI attempted to serve
the defendant with a subpoena, but were unable to locate her, on July 7, 2019. Prior to her arrest,
the Government and defense counsel communicated on multiple occasions between July and
October of 2019, and communicated briefly on two additional occasions, most recently in March
of 2020. At no point did defense counsel disclose the defendant’s location, offer to surrender the
defendant, or offer to bring the defendant in to be interviewed.
Moreover it is undisputed that when the FBI located the defendant, she ignored their
directives and ran away from the arresting agents. Although the defense has submitted an affidavit
from the defendant’s private security team, nothing in that affidavit should alter the Court’s
determination that detention is appropriate here. The defense already informed the Court at the
July 14, 2020 bail hearing that the defendant’s security protocol was to move to an inner room if
her security was breached. (Tr. 55). Even still, the new affidavit makes clear that the agents who
entered the defendant’s property were wearing clothing that clearly identified them as FBI agents.
directives and ran away from the arresting agents. Although the defense has submitted an affidavit
from the defendant’s private security team, nothing in that affidavit should alter the Court’s
determination that detention is appropriate here. The defense already informed the Court at the
July 14, 2020 bail hearing that the defendant’s security protocol was to move to an inner room if
her security was breached. (Tr. 55). Even still, the new affidavit makes clear that the agents who
entered the defendant’s property were wearing clothing that clearly identified them as FBI agents.
21
DOJ-OGR-00001166
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