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736 KB
Extraction Summary
4
People
3
Organizations
2
Locations
2
Events
2
Relationships
6
Quotes
Document Information
Type:
Legal filing (government opposition to renewed bail application)
File Size:
736 KB
Summary
This document is page 29 (filed 12/18/20) of a Government opposition to a renewed bail application in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The Government argues against release, citing the defendant's multiple foreign citizenships (including a non-extradition country), substantial wealth, and demonstrated sophistication in hiding assets as indicators of extreme flight risk. The document also defends the conditions of confinement at the MDC, noting the defendant has 13 hours a day to review discovery and access to attorney communications.
People (4)
| Name | Role | Context |
|---|---|---|
| The Defendant | Defendant |
Subject of the detention hearing; explicitly Ghislaine Maxwell based on Case 1:20-cr-00330-AJN, referred to with fema...
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| Epstein | Case Citation Subject |
Cited in legal precedent 'Epstein, 425 F. Supp. 3d at 326' regarding bail package evaluation.
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| Mercedes | Case Citation Subject |
Cited in legal precedent 'Mercedes, 254 F.3d at 436' regarding statutory presumption of detention.
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| Defense Counsel | Legal Representatives |
Attorneys for the defendant whom she communicates with via email and calls.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Government |
The party seeking continued detention of the defendant.
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| The Court |
The entity evaluating the bail package and arguments.
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| MDC |
Metropolitan Detention Center; where the defendant is currently confined.
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Locations (2)
| Location | Context |
|---|---|
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Metropolitan Detention Center, place of confinement.
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Defendant is a citizen of multiple countries, including one that does not extradite nationals.
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Relationships (2)
Defendant has access to email and calls with defense counsel.
Defendant is confined at the MDC and has specific privileges regarding discovery review.
Key Quotes (6)
"the crimes charged here involving minor victims trigger a statutory presumption in favor of detention"Source
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Quote #1
"Unlike the cases cited by the defense, the Government seeks detention not solely on the basis that the defendant is of financial means and has foreign citizenship."Source
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Quote #2
"detention is warranted because the defendant is a citizen of multiple foreign countries, including one that does not extradite its nationals"Source
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Quote #3
"demonstrated sophistication in hiding herself and her assets"Source
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Quote #4
"presents a substantial flight risk"Source
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Quote #5
"The defendant continues to have more time than any other inmate at the MDC to review her discovery specifically, the defendant currently has thirteen hours per day, seven days per week to review electronic discovery."Source
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Quote #6
Full Extracted Text
Complete text extracted from the document (2,173 characters)
Case 1:20-cr-00330-AJN Document 100 Filed 12/18/20 Page 32 of 36
United States). Further, unlike those cases and the cases cited by the defendant, the crimes charged here involving minor victims trigger a statutory presumption in favor of detention, weighing further in favor of detention. See Mercedes, 254 F.3d at 436.
“Each bail package in each case is considered and evaluated on its individual merits by the Court.” Epstein, 425 F. Supp. 3d at 326. Unlike the cases cited by the defense, the Government seeks detention not solely on the basis that the defendant is of financial means and has foreign citizenship. Rather, detention is warranted because the defendant is a citizen of multiple foreign countries, including one that does not extradite its nationals, with “substantial international ties,” “familial and personal connections abroad,” and “substantial financial resources,” (Tr. 83-84), with a demonstrated sophistication in hiding herself and her assets, who, for the myriad reasons discussed herein and identified at the original hearing—including the seriousness of the offense, the strength of the Government’s evidence, and the potential length of sentence—presents a substantial flight risk. (Tr. 82-91). The defendant continues to pose an extreme risk of flight, and the defense has not offered any new information sufficient to justify reversal of the Court’s prior finding that no combination of conditions could ensure her appearance.
D. Conditions of Confinement
Finally, the Renewed Bail Application reiterates the same argument about the potential harms of detention on the defendant that this Court rejected at the initial bail hearing. (Tr. 42, 68-69). As was the case in July, these complaints do not warrant the defendant’s release.
The defendant continues to have more time than any other inmate at the MDC to review her discovery and as much, if not more, time to communicate with her attorneys. Specifically, the defendant currently has thirteen hours per day, seven days per week to review electronic discovery. Also during that time, the defendant has access to email with defense counsel, calls with defense
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DOJ-OGR-00002193
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