DOJ-OGR-00002733.jpg
713 KB
Extraction Summary
4
People
2
Organizations
3
Locations
1
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal filing (memorandum in support of third motion for release on bail)
File Size:
713 KB
Summary
This document is page 2 of a legal filing dated February 23, 2021, representing Ghislaine Maxwell's introduction to her Third Motion for Release on Bail. In an effort to secure bail, Maxwell proposes two new restrictive conditions: renouncing her French and British citizenships to prevent flight to those countries, and consolidating her and her spouse's assets into a monitored account overseen by a retired federal judge or former US Attorney. She emphasizes her 30-year residency in the US and her desire to prepare for trial.
People (4)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Submitting a third motion for release on bail; proposing to renounce citizenships and monitor assets.
|
| Spouse of Ghislaine Maxwell | Family Member |
Mentioned regarding assets; Maxwell proposes placing her and her spouse's assets in a monitored account.
|
| Unnamed Retired Federal District Court Judge | Proposed Asset Monitor |
Proposed by Maxwell to monitor the new asset account.
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| Unnamed Former United States Attorney | Proposed Asset Monitor |
Proposed by Maxwell to monitor the new asset account and have co-signing authority.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| United States District Court |
The judicial body addressing the motion (SDNY implied by case number format, though not explicitly written on page).
|
|
| Department of Justice (DOJ) |
Implied by the footer stamp 'DOJ-OGR'.
|
Timeline (1 events)
2021-02-23
Filing of Memorandum in Support of Third Motion for Release on Bail
United States District Court
Locations (3)
| Location | Context |
|---|---|
|
Maxwell's country of residence for 30 years; where she wishes to remain for trial.
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|
|
Country of citizenship Maxwell proposes to renounce to avoid extradition concerns.
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Country of citizenship Maxwell proposes to renounce to avoid extradition concerns.
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Relationships (1)
Document refers to 'her and her spouse’s assets'.
Key Quotes (3)
"First, Ms. Maxwell will renounce her French and British citizenship to eliminate any opportunity for her to seek refuge in those countries, if the Court so requires."Source
DOJ-OGR-00002733.jpg
Quote #1
"Second, Ms. Maxwell will have her and her spouse’s assets... placed in a new account that will be monitored by a retired federal District Court judge and former United States Attorney who will function as asset monitor and will have co-signing authority over the account."Source
DOJ-OGR-00002733.jpg
Quote #2
"Ms. Maxwell has stated on numerous occasions and reaffirms here: she has no intention or desire to leave this country."Source
DOJ-OGR-00002733.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,085 characters)
Case 1:20-cr-00330-AJN Document 160 Filed 02/23/21 Page 2 of 9
INTRODUCTION
Ghislaine Maxwell respectfully submits this Memorandum in Support of her Third
Motion for Release on Bail.
Motion for Release on Bail.
As Ms. Maxwell has stated on numerous occasions and reaffirms here: she has no
intention or desire to leave this country. She is an American citizen, has lived in United States
for 30 years, has strong family ties and the support of friends and family residing in this country.
She wants nothing more than to remain in the United States under whatever conditions the Court
deems necessary so that she can effectively prepare for trial and vigorously defend against the
25-year-old charges in the Indictment. Ms. Maxwell has already proposed an expansive and, to
our knowledge, unprecedented set of bail conditions that would reasonably assure her
appearance. (See Dkt. 97.) In light of the Court’s denial of that application (see Dkt. 106), Ms.
Maxwell now proposes two additional bail conditions to supplement the extraordinarily
restrictive bail package she has already offered.
intention or desire to leave this country. She is an American citizen, has lived in United States
for 30 years, has strong family ties and the support of friends and family residing in this country.
She wants nothing more than to remain in the United States under whatever conditions the Court
deems necessary so that she can effectively prepare for trial and vigorously defend against the
25-year-old charges in the Indictment. Ms. Maxwell has already proposed an expansive and, to
our knowledge, unprecedented set of bail conditions that would reasonably assure her
appearance. (See Dkt. 97.) In light of the Court’s denial of that application (see Dkt. 106), Ms.
Maxwell now proposes two additional bail conditions to supplement the extraordinarily
restrictive bail package she has already offered.
• First, Ms. Maxwell will renounce her French and British citizenship to eliminate
any opportunity for her to seek refuge in those countries, if the Court so requires.
any opportunity for her to seek refuge in those countries, if the Court so requires.
• Second, Ms. Maxwell will have her and her spouse’s assets—excluding funds
earmarked for living expenses, for legal fees and other expenses necessary to
defend her against the criminal charges in this case and related civil lawsuits and
for taxes—placed in a new account that will be monitored by a retired federal
District Court judge and former United States Attorney who will function as asset
monitor and will have co-signing authority over the account.
earmarked for living expenses, for legal fees and other expenses necessary to
defend her against the criminal charges in this case and related civil lawsuits and
for taxes—placed in a new account that will be monitored by a retired federal
District Court judge and former United States Attorney who will function as asset
monitor and will have co-signing authority over the account.
The former condition goes well beyond the extradition waivers that the Court deemed
insufficient and should satisfy any concerns the Court may have that Ms. Maxwell may try to
seek a safe haven in France or the United Kingdom. (See id. at 11-13). As a non-citizen, Ms.
Maxwell will not be able to avail herself of any protections against extradition that may apply to
insufficient and should satisfy any concerns the Court may have that Ms. Maxwell may try to
seek a safe haven in France or the United Kingdom. (See id. at 11-13). As a non-citizen, Ms.
Maxwell will not be able to avail herself of any protections against extradition that may apply to
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DOJ-OGR-00002733
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