DOJ-OGR-00000952.jpg
526 KB
Extraction Summary
3
People
3
Organizations
5
Locations
3
Events
3
Relationships
5
Quotes
Document Information
Type:
Court filing / legal memorandum (detention memo)
File Size:
526 KB
Summary
This document is page 6 of a court filing (Case 1:20-cr-00330-AJN) arguing for the detention of a female defendant (identified by context as Ghislaine Maxwell). The prosecution argues she is a significant flight risk due to her wealth, multiple citizenships (US, UK, France), and possession of three passports. It notes she has taken at least 15 international flights in the last three years to locations including the UK, Japan, and Qatar.
People (3)
| Name | Role | Context |
|---|---|---|
| The Defendant | Defendant |
Subject of the detention hearing; described as female, born in France, raised in UK, naturalized US citizen (2002), h...
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| Pierre-Louis | Legal Precedent Subject |
Cited in case law United States v. Pierre-Louis.
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| Chief | Legal Precedent Subject |
Cited in case law United States v. Chief.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| United States Customs and Border Protection |
Source of travel records (CBP).
|
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| 9th Cir. |
Court cited in legal precedent.
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| S.D.N.Y. |
Southern District of New York (court cited in precedent).
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Timeline (3 events)
2017-2020
At least fifteen international flights in the last three years.
International (including UK, Japan, Qatar)
Locations (5)
| Location | Context |
|---|---|
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Defendant's birthplace and country of citizenship.
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Place where defendant was raised, attended school, holds citizenship, and traveled to.
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Country of naturalization and passport issuance.
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International travel destination mentioned in CBP records.
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International travel destination mentioned in CBP records.
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Relationships (3)
Naturalized citizen in 2002.
Born in France, remains a citizen.
Raised in UK, remains a citizen.
Key Quotes (5)
"the defendant’s extensive international ties would make it exceptionally easy for her to flee and live abroad."Source
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Quote #1
"the defendant was born in France and raised in the United Kingdom"Source
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Quote #2
"she also remains a citizen of the United Kingdom and France."Source
DOJ-OGR-00000952.jpg
Quote #3
"the defendant appears to possess passports from the United States, France, and the United Kingdom."Source
DOJ-OGR-00000952.jpg
Quote #4
"creates an extraordinary incentive to flee."Source
DOJ-OGR-00000952.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (2,211 characters)
Case 1:20-cr-00330-AJN Document 20 Filed 07/02/20 Page 6 of 20
date of the amendment,¹ to permit a prosecution at any point during the lifetime of the minor
victim. See United States v. Chief, 438 F.3d 920, 922-25 (9th Cir. 2006) (finding that because
Congress extended the statute of limitations for sex offenses involving minors during the time the
previous statute was still running, the extension was permissible); United States v. Pierre-Louis,
No. 16 Cr. 541 (CM), 2018 WL 4043140, at *1 (S.D.N.Y. Aug. 9, 2018) (same). Moreover, while
the conduct alleged in the Indictment may have occurred years ago, the risk of a significant term
of incarceration – and thus the motive to flee – is of course only very recent.
victim. See United States v. Chief, 438 F.3d 920, 922-25 (9th Cir. 2006) (finding that because
Congress extended the statute of limitations for sex offenses involving minors during the time the
previous statute was still running, the extension was permissible); United States v. Pierre-Louis,
No. 16 Cr. 541 (CM), 2018 WL 4043140, at *1 (S.D.N.Y. Aug. 9, 2018) (same). Moreover, while
the conduct alleged in the Indictment may have occurred years ago, the risk of a significant term
of incarceration – and thus the motive to flee – is of course only very recent.
Each of these factors – the seriousness of the allegations, the strength of the evidence, and
the possibility of lengthy incarceration – creates an extraordinary incentive to flee. And as further
described below, the defendant has the means and money to do so.
the possibility of lengthy incarceration – creates an extraordinary incentive to flee. And as further
described below, the defendant has the means and money to do so.
B. The Characteristics of the Defendant
The history and characteristics of the defendant also strongly support detention. As an
initial matter, the defendant’s extensive international ties would make it exceptionally easy for her
to flee and live abroad. The defendant was born in France and raised in the United Kingdom,
where she attended school. Although she became a naturalized citizen of the United States in
2002, she also remains a citizen of the United Kingdom and France. Travel records from
United States Customs and Border Protection (“CBP”) reflect that she has engaged in frequent
international travel, including at least fifteen international flights in the last three years to locations
including the United Kingdom, Japan, and Qatar. In addition, CBP records reflect that, consistent
with her citizenship status, the defendant appears to possess passports from the United States,
France, and the United Kingdom.
initial matter, the defendant’s extensive international ties would make it exceptionally easy for her
to flee and live abroad. The defendant was born in France and raised in the United Kingdom,
where she attended school. Although she became a naturalized citizen of the United States in
2002, she also remains a citizen of the United Kingdom and France. Travel records from
United States Customs and Border Protection (“CBP”) reflect that she has engaged in frequent
international travel, including at least fifteen international flights in the last three years to locations
including the United Kingdom, Japan, and Qatar. In addition, CBP records reflect that, consistent
with her citizenship status, the defendant appears to possess passports from the United States,
France, and the United Kingdom.
________________________
¹ Prior to the amendment, the statute of limitations for sexual offenses involving minors ran until
the victim reached the age of 25, and as such, all of the relevant charges in the Indictment
remained timely as of the 2003 amendment described above.
¹ Prior to the amendment, the statute of limitations for sexual offenses involving minors ran until
the victim reached the age of 25, and as such, all of the relevant charges in the Indictment
remained timely as of the 2003 amendment described above.
6
DOJ-OGR-00000952
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