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Extraction Summary
3
People
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Organizations
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Locations
1
Events
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Relationships
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Quotes
Document Information
Type:
Legal filing (court memorandum/motion reply)
File Size:
614 KB
Summary
This is page 6 of a legal defense filing (Reply Memorandum) dated December 28, 2020, in the case of United States v. Ghislaine Maxwell. The defense argues against the government's claim that Maxwell is hiding assets to prepare for flight, stating that her transfers to her spouse were disclosed on tax returns and that her asset estimates from jail were accurate given the circumstances. The document details financial specifics, including a London property used for loans and $4 million controlled by her spouse, with specific details regarding the spouse's assets redacted.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the legal arguments regarding bail, assets, and flight risk.
|
| Spouse | Family Member |
Husband of Maxwell; recipient of asset transfers; controls $4 million in assets.
|
| Pretrial Services | Government Agency Personnel |
Interviewed Maxwell in jail to estimate her assets.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Pretrial Services |
Agency responsible for assessing defendant's financial status.
|
|
| The government |
The prosecution (Department of Justice/US Attorney's Office).
|
Timeline (1 events)
Relationships (1)
Reference to 'joint tax returns', transfers of assets to spouse, and spouse controlling $4 million.
Key Quotes (4)
"The government asserts that Ms. Maxwell has demonstrated 'sophistication in hiding her assets' and characterizes her transfers to a trust as 'funneling' assets to her spouse to 'hide her true wealth.'"Source
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Quote #1
"Ms. Maxwell fully disclosed these transactions on her joint tax returns."Source
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Quote #2
"Ms. Maxwell has procured significant loans on the basis of a negative pledge over her London property."Source
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Quote #3
"Second, the $4 million controlled by her spouse [REDACTED] could only be liquidated with considerable difficulty."Source
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Full Extracted Text
Complete text extracted from the document (2,266 characters)
Case 1:20-cr-00330-AJN Document 103-2 Filed 12/28/20 Page 6 of 15
The report shows nothing of the sort. Ms. Maxwell, who was sitting in a jail cell at the time,
was asked by Pretrial Services to estimate her assets. Accordingly, she gave her best
estimate of the assets she held in her own name, which the government concedes she did
with remarkable accuracy considering that she had not reviewed her financial statements.⁵
was asked by Pretrial Services to estimate her assets. Accordingly, she gave her best
estimate of the assets she held in her own name, which the government concedes she did
with remarkable accuracy considering that she had not reviewed her financial statements.⁵
The government’s arguments further confirm that it has lost all objectivity and will
view at any fact involving Ms. Maxwell in the worst possible light. For example, the
government asserts that Ms. Maxwell has demonstrated “sophistication in hiding her assets”
and characterizes her transfers to a trust as “funneling” assets to her spouse to “hide her true
wealth.” (Id. at 24). There is nothing unusual, let alone nefarious or even particularly
sophisticated about transferring assets into a trust or a spouse. Indeed, Ms. Maxwell fully
disclosed these transactions on her joint tax returns. More importantly, all of the assets
disclosed in the financial report, whether they are owned by Ms. Maxwell or her spouse, are
included in the bond amount and are subject to forfeiture if she flees.
view at any fact involving Ms. Maxwell in the worst possible light. For example, the
government asserts that Ms. Maxwell has demonstrated “sophistication in hiding her assets”
and characterizes her transfers to a trust as “funneling” assets to her spouse to “hide her true
wealth.” (Id. at 24). There is nothing unusual, let alone nefarious or even particularly
sophisticated about transferring assets into a trust or a spouse. Indeed, Ms. Maxwell fully
disclosed these transactions on her joint tax returns. More importantly, all of the assets
disclosed in the financial report, whether they are owned by Ms. Maxwell or her spouse, are
included in the bond amount and are subject to forfeiture if she flees.
The government further argues that the financial condition report shows that Ms.
Maxwell has access to millions of dollars of “unrestrained funds” that she could use to flee
the country and reimburse any of her sureties for the loss of their security. (Id. at 23). That
characterization is simply untrue. First, as disclosed in the financial report, Ms. Maxwell
has procured significant loans on the basis of a negative pledge over her London property.
Second, the $4 million controlled by her spouse [REDACTED]
could only be liquidated with considerable difficulty.
Maxwell has access to millions of dollars of “unrestrained funds” that she could use to flee
the country and reimburse any of her sureties for the loss of their security. (Id. at 23). That
characterization is simply untrue. First, as disclosed in the financial report, Ms. Maxwell
has procured significant loans on the basis of a negative pledge over her London property.
Second, the $4 million controlled by her spouse [REDACTED]
could only be liquidated with considerable difficulty.
The government also faults Ms. Maxwell for not including a valuation of future
contingent assets and income that may never materialize. (Id. at 23-24). For example, [REDACTED]
contingent assets and income that may never materialize. (Id. at 23-24). For example, [REDACTED]
__________________________________________________________________
⁵ Moreover, for the reasons discussed in our initial memorandum, Ms. Maxwell was reluctant to discuss anything
about her spouse and clearly expressed her reluctance to Pretrial Services early on in the interview.
⁵ Moreover, for the reasons discussed in our initial memorandum, Ms. Maxwell was reluctant to discuss anything
about her spouse and clearly expressed her reluctance to Pretrial Services early on in the interview.
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DOJ-OGR-00001195
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