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641 KB
Extraction Summary
3
People
2
Organizations
1
Locations
1
Events
1
Relationships
5
Quotes
Document Information
Type:
Legal defense filing (bail motion/reply)
File Size:
641 KB
Summary
This document is page 11 of a legal filing (Document 103) dated December 23, 2020, in the case of United States v. Ghislaine Maxwell. The defense argues for Maxwell's release on bail, stating she and her spouse have pledged all assets and that her wealth suggests strict conditions rather than denial of bail. It refutes the government's claim that she is a flight risk or adept at hiding, and clarifies financial details regarding her spouse's assets and banking records.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the bail hearing; defense argues she is not a flight risk and has proposed a substantial bail package.
|
| Unidentified Spouse | Spouse/Co-signer |
Has pledged assets, liquidated investments to help Maxwell, and is discussed in the context of financial forfeiture i...
|
| The Government | Prosecution |
Opposing bail, asserting Maxwell is adept at hiding and a flight risk.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| The Government |
Referring to the Department of Justice/Prosecutors.
|
|
| Defense Team |
Implied authors of the document arguing for bail.
|
Timeline (1 events)
Locations (1)
| Location | Context |
|---|---|
|
Implied United States (context of leaving the country).
|
Relationships (1)
Document mentions 'her spouse' pledging assets and liquidating investments for her defense.
Key Quotes (5)
"Ms. Maxwell has proposed a substantial bail package with multiple co-signers and significant security."Source
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Quote #1
"Ms. Maxwell’s wealth is not a reason to deny her bail."Source
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Quote #2
"The government continues to assert the sinister narrative that Ms. Maxwell had 'an expertise at remaining hidden,' and that it would therefore be easy for her to become a fugitive."Source
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Quote #3
"Regardless of whose money it was to begin with, all of the assets of Ms. Maxwell and her spouse will be forfeited if she flees"Source
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Quote #4
"Her spouse... has had to liquidate his existing investments to help Ms. Maxwell."Source
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Quote #5
Full Extracted Text
Complete text extracted from the document (2,019 characters)
Case 1:20-cr-00330-AJN Document 103 Filed 12/23/20 Page 11 of 15
[Redacted]
[Redacted]
[Redacted] Similarly, the financial report does not include
a future income stream for Ms. Maxwell or her spouse because it presents only historical
and current assets. Even so, Ms. Maxwell has no certain future income stream. Her spouse
[Redacted]
[Redacted] and has had to liquidate his existing investments to help Ms. Maxwell. Finally, the
reference to [Redacted] is gratuitous. Ms. Maxwell had no knowledge of [Redacted]
[Redacted]
[Redacted]
[Redacted]
[Redacted]
[Redacted] Similarly, the financial report does not include
a future income stream for Ms. Maxwell or her spouse because it presents only historical
and current assets. Even so, Ms. Maxwell has no certain future income stream. Her spouse
[Redacted]
[Redacted] and has had to liquidate his existing investments to help Ms. Maxwell. Finally, the
reference to [Redacted] is gratuitous. Ms. Maxwell had no knowledge of [Redacted]
[Redacted]
[Redacted]
[Redacted]
But the larger point is this: Ms. Maxwell has proposed a substantial bail package
with multiple co-signers and significant security. She and her spouse have pledged all of
their assets in support of the bond. Ms. Maxwell’s wealth is not a reason to deny her bail. It
is a reason to set appropriately strict conditions that will result in significant financial
consequences to Ms. Maxwell and her friends and family if she leaves the country. The
proposed bail package does exactly that.⁶
with multiple co-signers and significant security. She and her spouse have pledged all of
their assets in support of the bond. Ms. Maxwell’s wealth is not a reason to deny her bail. It
is a reason to set appropriately strict conditions that will result in significant financial
consequences to Ms. Maxwell and her friends and family if she leaves the country. The
proposed bail package does exactly that.⁶
C. The Government’s Assertion that Ms. Maxwell Is “Adept” at Hiding and
Therefore a Flight Risk Is Specious
Therefore a Flight Risk Is Specious
The government continues to assert the sinister narrative that Ms. Maxwell had “an
expertise at remaining hidden,” and that it would therefore be easy for her to become a fugitive.
expertise at remaining hidden,” and that it would therefore be easy for her to become a fugitive.
__________________
⁶ The government’s argument that her spouse’s moral suasion is diminished because Ms. Maxwell brought the
majority of assets to the relationship is nonsensical. (Id. at 24-25). Regardless of whose money it was to begin with,
all of the assets of Ms. Maxwell and her spouse will be forfeited if she flees and her spouse [Redacted] will be
left with nothing. Furthermore, the government’s assertion that they could not verify the spouse’s financial
information because Ms. Maxwell did not provide his current banking information is false. (Id. at 24 n.9). The
defense provided the spouse’s current banking records and only redacted the name of the bank.
⁶ The government’s argument that her spouse’s moral suasion is diminished because Ms. Maxwell brought the
majority of assets to the relationship is nonsensical. (Id. at 24-25). Regardless of whose money it was to begin with,
all of the assets of Ms. Maxwell and her spouse will be forfeited if she flees and her spouse [Redacted] will be
left with nothing. Furthermore, the government’s assertion that they could not verify the spouse’s financial
information because Ms. Maxwell did not provide his current banking information is false. (Id. at 24 n.9). The
defense provided the spouse’s current banking records and only redacted the name of the bank.
7
DOJ-OGR-00002217
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