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Extraction Summary
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People
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Organizations
2
Locations
3
Events
1
Relationships
5
Quotes
Document Information
Type:
Legal filing (bail application/memorandum)
File Size:
522 KB
Summary
This document is page 35 of a legal filing (Document 102) dated December 14, 2020, arguing for Ghislaine Maxwell's release on bail. The defense asserts she is not a flight risk and argues that her current detention at the MDC constitutes 'de facto solitary confinement' under conditions rivaling a Supermax prison, which impairs her ability to prepare her defense. The text cites United States v. Orta regarding bail standards and claims wardens have noted the unprecedented nature of her restrictive regime.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the bail application, arguing against flight risk and describing poor prison conditions.
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| Jeffrey Epstein | Associate |
Mentioned in reference to the timeline of events ('since Epstein's arrest').
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| Wardens/Interim Wardens | Prison Officials |
Unnamed officials who reportedly remarked on the severity of Maxwell's confinement regime.
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Organizations (4)
| Name | Type | Context |
|---|---|---|
| MDC |
Metropolitan Detention Center, where Maxwell is currently held.
|
|
| USP Florence ADMAX |
Supermax prison used as a comparison for the severity of Maxwell's conditions.
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| 8th Circuit Court |
Cited in legal precedent (United States v. Orta).
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| Department of Justice (DOJ) |
Indicated by the footer stamp 'DOJ-OGR'.
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Timeline (3 events)
Locations (2)
| Location | Context |
|---|---|
Relationships (1)
Reference to 'Epstein's arrest' impacting her family situation.
Key Quotes (5)
"Ms. Maxwell has no intention of fleeing."Source
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Quote #1
"The alternative to release is her continued confinement under extraordinarily onerous conditions that are not only unjust and punitive, but also meaningfully impair Ms. Maxwell’s ability to review the voluminous discovery produced by the government"Source
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Quote #2
"Ms. Maxwell has spent the entirety of her detention now over five months in de facto solitary confinement"Source
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Quote #3
"conditions that rival those used at USP Florence ADMAX"Source
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Quote #4
"tantamount to imprisonment as a defendant convicted of capital murder and incarcerated on death row."Source
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Quote #5
Full Extracted Text
Complete text extracted from the document (2,157 characters)
Case 1:20-cr-00330-AJN Document 102 Filed 12/14/20 Page 41 of 45
11-12). Ms. Maxwell is not obligated to rebut every theoretical possibility that the government might raise that may contribute to a potential flight risk in order to be granted bail. That is not the standard. Cf. United States v. Orta, 760 F.2d 887, 888 n.4, 892-93 (8th Cir. 1985) (“The legal standard required by the [Bail Reform] Act is one of reasonable assurances, not absolute guarantees.”). Ms. Maxwell has no intention of fleeing. If she did, then under the proposed bail conditions she would lose everything and destroy the family she has been fighting so hard to protect since Epstein’s arrest. Ms. Maxwell will not do that, and should be granted bail.
G. The Alternative to Bail Is Confinement Under Oppressive Conditions that Impact Ms. Maxwell’s Health and Ability to Prepare Her Defense
Granting bail to Ms. Maxwell is all the more appropriate and necessary because the past few months have shown that Ms. Maxwell cannot adequately participate in her defense and prepare for trial from the inside the MDC. The alternative to release is her continued confinement under extraordinarily onerous conditions that are not only unjust and punitive, but also meaningfully impair Ms. Maxwell’s ability to review the voluminous discovery produced by the government and to communicate effectively with counsel to prepare her defense.
Ms. Maxwell has spent the entirety of her detention now over five months in de facto solitary confinement, under conditions that rival those used at USP Florence ADMAX to supervise the most dangerous inmates in the federal system and are tantamount to imprisonment as a defendant convicted of capital murder and incarcerated on death row. In fact, multiple wardens and interim wardens have remarked that in their collective years of experience they have never seen anything like her current regime. The restrictive regulations to which Ms. Maxwell is subjected are not reasonably related to a legitimate goal to ensure the security of Ms. Maxwell or the MDC. Instead, it seems clear that the overly restrictive conditions are an
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DOJ-OGR-00020055
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