DOJ-OGR-00001988.jpg
698 KB
Extraction Summary
4
People
3
Organizations
1
Locations
3
Events
2
Relationships
6
Quotes
Document Information
Type:
Court filing / legal memorandum (bail application)
File Size:
698 KB
Summary
This document is a legal memorandum filed on December 14, 2020, arguing for Ghislaine Maxwell's release on bail (Case 1:20-cr-00330-AJN). It asserts that Maxwell has deep ties to the U.S., specifically through her spouse (whose name is redacted), and is supported by letters from family and friends willing to post significant financial assets as sureties. The defense argues these letters counter the 'cruel caricature' of Maxwell in the press and address the Court's previous concerns regarding her lack of dependents or ties to the country.
People (4)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the bail application, described as generous, loving, and devoted by supporters.
|
| Jeffrey Epstein | Associate (Deceased) |
Mentioned regarding the timing of press depictions of Maxwell since his arrest.
|
| [Redacted] | Spouse |
Maxwell's spouse, mentioned as a primary tie to the US and submitter of a support letter.
|
| Sureties | Supporters |
Unnamed close family members and friends providing letters and financial pledges.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Court |
Referenced regarding concerns expressed at a previous bail hearing.
|
|
| The Government |
Referenced regarding allegations made against Maxwell.
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|
| DOJ |
Department of Justice (referenced in Bates stamp DOJ-OGR-00001988).
|
Timeline (3 events)
Locations (1)
| Location | Context |
|---|---|
|
Country where Maxwell claims to have deep family ties and roots.
|
Relationships (2)
Text refers to 'her spouse' multiple times and states her life is rooted with him.
Signatories have known her for decades or entire life; trust her with minor children.
Key Quotes (6)
"Ms. Maxwell Has Deep Family Ties to the United States and Numerous Sureties to Support Her Bond"Source
DOJ-OGR-00001988.jpg
Quote #1
"Far from the cruel caricature that the press has so recklessly depicted since the arrest of Jeffrey Epstein, these letters demonstrate that Ms. Maxwell is generous, loving, and devoted to her family and friends"Source
DOJ-OGR-00001988.jpg
Quote #2
"her life is firmly rooted in this country with her spouse [REDACTED]"Source
DOJ-OGR-00001988.jpg
Quote #3
"All know her to be the antithesis of what the government has alleged."Source
DOJ-OGR-00001988.jpg
Quote #4
"the sureties have agreed to sign their own bonds and to post meaningful pledges of cash or property in amounts that would cause them significant financial distress"Source
DOJ-OGR-00001988.jpg
Quote #5
"If Ms. Maxwell were to flee... she would be abandoning her spouse [REDACTED]."Source
DOJ-OGR-00001988.jpg
Quote #6
Full Extracted Text
Complete text extracted from the document (1,960 characters)
Case 1:20-cr-00330-AJN Document 97 Filed 12/14/20 Page 16 of 45
II. Ms. Maxwell Should Be Granted Bail Under the Proposed Strict Bail Conditions
A. Ms. Maxwell Has Deep Family Ties to the United States and Numerous Sureties to Support Her Bond
Attached to this submission are letters from Ms. Maxwell’s spouse and from numerous close family members and friends, many of whom have agreed to serve as sureties to support Ms. Maxwell’s renewed bail application. (See Exs. A-N, W-X). Far from the cruel caricature that the press has so recklessly depicted since the arrest of Jeffrey Epstein, these letters demonstrate that Ms. Maxwell is generous, loving, and devoted to her family and friends, and that her life is firmly rooted in this country with her spouse [REDACTED]. The signatories of these letters have known Ms. Maxwell for decades, and some for her entire life. All know her to be the antithesis of what the government has alleged. They trust her completely, including with their minor children.
These people have stepped forward to support Ms. Maxwell, despite the considerable risk that, if their names ever become public, they will be subjected to some of the same relentless and harassing media intrusion and personal threats that Ms. Maxwell has experienced for years. As a sign of their confidence that Ms. Maxwell will remain in this country, the sureties have agreed to sign their own bonds and to post meaningful pledges of cash or property in amounts that would cause them significant financial distress if Ms. Maxwell were to violate her bail conditions.
These letters directly address the concern the Court expressed at the last bail hearing that Ms. Maxwell did not have “any dependents [or] significant family ties” to the United States. (Tr. 84). If Ms. Maxwell were to flee, she would be leaving behind the family that has been the center of her life [REDACTED], she would be abandoning her spouse [REDACTED].
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DOJ-OGR-00001988
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