DOJ-OGR-00000955.jpg

354 KB

Extraction Summary

6
People
5
Organizations
1
Locations
1
Events
3
Relationships
4
Quotes

Document Information

Type: Legal filing (government submission/memorandum)
File Size: 354 KB
Summary

This document is the conclusion page of a legal memorandum submitted by the United States Government on July 2, 2020, in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). The filing argues that the defendant poses an 'extreme risk of flight' and requests that any application for bail be denied, asserting that no conditions would assure the defendant's presence in court. It is signed by Assistant US Attorney Alison Moe on behalf of Acting US Attorney Audrey Strauss.

People (6)

Name Role Context
Audrey Strauss Acting United States Attorney
Signatory authority for the government's submission
Alison Moe Assistant United States Attorney
Signatory of the document
Alex Rossmiller Assistant United States Attorney
Listed as counsel for the government
Maurene Comey Assistant United States Attorney
Listed as counsel for the government
The Defendant Defendant
Subject of the detention request (Contextually Ghislaine Maxwell based on Case 1:20-cr-00330-AJN)
Gleeson, J. Judge
Cited in a legal precedent (E.D.N.Y. Aug. 4, 2000)

Organizations (5)

Name Type Context
United States Attorney's Office
Southern District of New York (implied by signatories)
Department of Justice
Indicated by Bates stamp DOJ-OGR
E.D.N.Y.
Eastern District of New York (Court cited)
N.D. Cal.
Northern District of California (Court cited)
D.D.C.
District Court for the District of Columbia (Court cited)

Timeline (1 events)

2020-07-02
Government submission of memorandum arguing for detention without bail
New York, New York

Locations (1)

Location Context
Location where the document was dated and submitted

Relationships (3)

Alison Moe Professional/Legal Audrey Strauss
Moe signs on behalf of the office led by Acting US Attorney Strauss
Alison Moe Colleagues Alex Rossmiller
Listed together as Assistant United States Attorneys
Alison Moe Colleagues Maurene Comey
Listed together as Assistant United States Attorneys

Key Quotes (4)

"As set forth above, the defendant is an extreme risk of flight."
Source
DOJ-OGR-00000955.jpg
Quote #1
"The Government respectfully submits that the defendant cannot meet her burden of overcoming the statutory presumption in favor of detention."
Source
DOJ-OGR-00000955.jpg
Quote #2
"There are no conditions of bail that would assure the defendant’s presence in court proceedings in this case."
Source
DOJ-OGR-00000955.jpg
Quote #3
"Accordingly, any application for bail should be denied."
Source
DOJ-OGR-00000955.jpg
Quote #4

Full Extracted Text

Complete text extracted from the document (1,162 characters)

Case 1:20-cr-00330-AJN Document 14 Filed 07/02/20 Page 10 of 10
(E.D.N.Y. Aug. 4, 2000) (Gleeson, J.) (rejecting defendant’s application for bail in part because home detention with electronic monitoring “at best . . . limits a fleeing defendant’s head start”); United States v. Benatar, No. 02 Cr. 099, 2002 WL 31410262, at *3 (E.D.N.Y. Oct. 10, 2002) (same); see also United States v. Casteneda, No. 18 Cr. 047, 2018 WL 888744, at *9 (N.D. Cal. Feb. 2018) (same); United States v. Anderson, 384 F. Supp. 2d 32, 41 (D.D.C. 2005) (same).
CONCLUSION
As set forth above, the defendant is an extreme risk of flight. The Government respectfully submits that the defendant cannot meet her burden of overcoming the statutory presumption in favor of detention. There are no conditions of bail that would assure the defendant’s presence in court proceedings in this case. Accordingly, any application for bail should be denied.
Dated: New York, New York
July 2, 2020
Respectfully submitted,
AUDREY STRAUSS
Acting United States Attorney
By: Alison G. Moe
Alison Moe
Alex Rossmiller
Maurene Comey
Assistant United States Attorneys
(212) 637-2225
9
DOJ-OGR-00000955

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