DOJ-OGR-00001125.jpg
496 KB
Extraction Summary
5
People
3
Organizations
2
Locations
2
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal filing / defense motion (page 23 of a larger document, page 29 of pdf)
File Size:
496 KB
Summary
This document is a page from a defense motion filed on December 14, 2020, arguing that Ghislaine Maxwell did not attempt to evade arrest or flee. Defense counsel claims the 'raid' on her New Hampshire home was unnecessary and theatrical, timed to the anniversary of Epstein's arrest. It addresses specific allegations, such as a cell phone wrapped in tin foil, explaining these were security measures against the press, supported by a statement from the (redacted) head of her security team.
People (5)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the arrest and defense arguments regarding flight risk and intent.
|
| Jeffrey Epstein | Deceased Financier |
Mentioned regarding the one-year anniversary of his arrest coinciding with Maxwell's arrest.
|
| [Redacted] | Head of Security Company |
Provided a statement (Exhibit S) regarding Maxwell's actions during the arrest.
|
| Defense Counsel | Legal Team |
Argues they would have arranged self-surrender if asked.
|
| Government / Prosecutors | Prosecution |
Accused of creating a misimpression of Maxwell hiding and conducting an unnecessary raid.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Court |
Recipient of the arguments.
|
|
| Department of Justice (DOJ) |
Implied by footer DOJ-OGR.
|
|
| Security Company |
Unnamed firm guarding Maxwell at the time of arrest.
|
Timeline (2 events)
2019-07-06 (Implied)
2020-07-02 (Implied)
Arrest of Ghislaine Maxwell (described as 'early morning raid').
New Hampshire residence
Ghislaine Maxwell
Federal Agents
Locations (2)
| Location | Context |
|---|---|
|
Location of Ms. Maxwell's residence and arrest.
|
|
|
Specific location within the NH residence where Maxwell moved during the raid.
|
Relationships (2)
[Redacted] is the head of the security company guarding Ms. Maxwell
Arrest timed to anniversary of Epstein's arrest.
Key Quotes (5)
"Ms. Maxwell Did Not Try to Avoid Arrest, Nor Was She 'Good At' Hiding"Source
DOJ-OGR-00001125.jpg
Quote #1
"Instead, the government arrested her in a totally unnecessary early morning raid with multiple federal agents at her residence in New Hampshire"Source
DOJ-OGR-00001125.jpg
Quote #2
"creating the misimpression that Ms. Maxwell was hiding from them."Source
DOJ-OGR-00001125.jpg
Quote #3
"they found a cell phone wrapped in tin foil"Source
DOJ-OGR-00001125.jpg
Quote #4
"Ms. Maxwell was not avoiding arrest, but was following an agreed-upon procedure to protect herself in the event of a potential threat to her safety or security."Source
DOJ-OGR-00001125.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (1,990 characters)
Case 1:20-cr-00330-AJN Document 102 Filed 12/14/20 Page 29 of 45
The government argued to the Court that defense counsel’s contact with the
prosecutors in the months leading up to Ms. Maxwell’s arrest prove little about her intent to
stay in this country simply because she never disclosed her location. (Tr. 26). While Ms.
Maxwell was understandably not in the habit of volunteering her whereabouts given the
intensity of the press attention, her counsel would have provided that information had the
government asked for it. The government never did.
prosecutors in the months leading up to Ms. Maxwell’s arrest prove little about her intent to
stay in this country simply because she never disclosed her location. (Tr. 26). While Ms.
Maxwell was understandably not in the habit of volunteering her whereabouts given the
intensity of the press attention, her counsel would have provided that information had the
government asked for it. The government never did.
3. Ms. Maxwell Did Not Try to Avoid Arrest, Nor Was She “Good At”
Hiding
Hiding
Similarly, had the government reached out to defense counsel before Ms. Maxwell’s
arrest, we would have willingly arranged for her self-surrender. We were never given that
chance. Instead, the government arrested her in a totally unnecessary early morning raid
with multiple federal agents at her residence in New Hampshire, on the eve of the one-year
anniversary of the arrest of Jeffrey Epstein, creating the misimpression that Ms. Maxwell
was hiding from them. That is simply not the case.
arrest, we would have willingly arranged for her self-surrender. We were never given that
chance. Instead, the government arrested her in a totally unnecessary early morning raid
with multiple federal agents at her residence in New Hampshire, on the eve of the one-year
anniversary of the arrest of Jeffrey Epstein, creating the misimpression that Ms. Maxwell
was hiding from them. That is simply not the case.
The government argued that the events of Ms. Maxwell’s arrest—in particular, that
she moved herself into an interior room when the officers approached the house and that
they found a cell phone wrapped in tin foil—evidence an attempt to evade law enforcement.
(Tr. 32-34). As we previously explained to the Court, Ms. Maxwell was protecting herself
from the press, not trying to avoid arrest. (Tr. 54-57).
she moved herself into an interior room when the officers approached the house and that
they found a cell phone wrapped in tin foil—evidence an attempt to evade law enforcement.
(Tr. 32-34). As we previously explained to the Court, Ms. Maxwell was protecting herself
from the press, not trying to avoid arrest. (Tr. 54-57).
Since the hearing, we have obtained the accompanying statement from [REDACTED]
[REDACTED] the head of the security company guarding Ms. Maxwell at the time of her arrest,
which was not available at the time of the initial hearing. (Ex. S). [REDACTED] statement
demonstrates that Ms. Maxwell was not avoiding arrest, but was following an agreed-upon
procedure to protect herself in the event of a potential threat to her safety or security.
[REDACTED] the head of the security company guarding Ms. Maxwell at the time of her arrest,
which was not available at the time of the initial hearing. (Ex. S). [REDACTED] statement
demonstrates that Ms. Maxwell was not avoiding arrest, but was following an agreed-upon
procedure to protect herself in the event of a potential threat to her safety or security.
23
DOJ-OGR-00001125
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