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508 KB
Extraction Summary
3
People
2
Organizations
3
Locations
3
Events
1
Relationships
5
Quotes
Document Information
Type:
Legal filing / court motion (defense reply in support of bail)
File Size:
508 KB
Summary
This document is a page from a legal defense filing (Case 1:20-cr-00330-AJN) arguing for Ghislaine Maxwell's release on bail. The defense contends that Maxwell was not evading law enforcement but rather the press, evidenced by her use of a trackable cellphone. It further argues she is not a flight risk to France or the UK because she has irrevocably waived extradition rights and chose to remain in the US following Jeffrey Epstein's arrest and death.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the bail hearing; defense argues she is not a flight risk and was hiding from press, not law enforcement.
|
| Jeffrey Epstein | Deceased Associate |
Mentioned in context of his arrest and death, after which Maxwell did not flee.
|
| [REDACTED] | Unknown (likely spouse/guarantor) |
Person in whose 'plain sight' Maxwell would remain at home under proposed bail conditions.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| United States Government/DOJ |
Prosecution arguing against bail.
|
|
| The Press |
Cited as the reason Maxwell was hiding.
|
Timeline (3 events)
2020-12-14 (Filing Date)
Filing of Document 120 in Case 1:20-cr-00330-AJN
Court
Defense Counsel
Court
Locations (3)
| Location | Context |
|---|---|
|
Where Maxwell has lived for almost 30 years; jurisdiction of the court.
|
|
|
Potential flight destination discussed regarding extradition laws.
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|
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Potential flight destination discussed regarding non-extradition of citizens.
|
Relationships (1)
Document mentions she did not flee after his arrest and death.
Key Quotes (5)
"the cellphone clearly shows that Ms. Maxwell was not “good at” hiding or that she was avoiding arrest"Source
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Quote #1
"She was trying to protect herself as best as she could from harassment by the press, not capture by law enforcement."Source
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Quote #2
"Ms. Maxwell Has Waived Her Extradition Rights and Could Not Seek Refuge in the United Kingdom or France"Source
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Quote #3
"France will not extradite a French citizen to the United States as a matter of law"Source
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Quote #4
"Ms. Maxwell had every motive and opportunity to flee after the arrest and death of Jeffrey Epstein, but chose to remain in this"Source
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Quote #5
Full Extracted Text
Complete text extracted from the document (2,090 characters)
Case 1:20-cr-00330-AJN Document 120 Filed 12/14/20 Page 31 of 45
Indeed, the discovery reflects that it was not hard at all for the government to locate Ms.
Maxwell when they wanted to find her by tracking her primary phone.
Maxwell when they wanted to find her by tracking her primary phone.
In sum, the cellphone clearly shows that Ms. Maxwell was not “good at” hiding or
that she was avoiding arrest, as the government claimed. (Tr. 31-32). She was trying to
protect herself as best as she could from harassment by the press, not capture by law
enforcement. Moreover, this should not be a bar to granting bail. The proposed conditions
ensure her presence at home in plain sight of [REDACTED] (and the security guards), GPS-
monitored, and under strict Pretrial supervision.
that she was avoiding arrest, as the government claimed. (Tr. 31-32). She was trying to
protect herself as best as she could from harassment by the press, not capture by law
enforcement. Moreover, this should not be a bar to granting bail. The proposed conditions
ensure her presence at home in plain sight of [REDACTED] (and the security guards), GPS-
monitored, and under strict Pretrial supervision.
D. Ms. Maxwell Has Waived Her Extradition Rights and Could Not Seek
Refuge in the United Kingdom or France
Refuge in the United Kingdom or France
At the initial hearing, the government argued that Ms. Maxwell, a naturalized U.S. citizen
who has lived in the United States for almost 30 years, might flee to the United Kingdom or
France if granted bail, despite the fact that she did not leave the country for nearly a year after
Epstein’s arrest. (Dkt. 22 at 6.) The government asserted in its reply brief that France “does not
extradite its citizens to the United States pursuant to French law.” (Id.) At the bail hearing, the
government represented that “France will not extradite a French citizen to the United States as a
matter of law, even if the defendant is a dual citizen of the United States,” and that extradition by
the United Kingdom would be “lengthy” and “uncertain” with bail “very likely” pending the
extradition proceeding. (Tr. 27.) These assertions are incorrect, particularly given Ms.
Maxwell’s irrevocable waiver of her extradition rights with respect to both the United Kingdom
and France.
who has lived in the United States for almost 30 years, might flee to the United Kingdom or
France if granted bail, despite the fact that she did not leave the country for nearly a year after
Epstein’s arrest. (Dkt. 22 at 6.) The government asserted in its reply brief that France “does not
extradite its citizens to the United States pursuant to French law.” (Id.) At the bail hearing, the
government represented that “France will not extradite a French citizen to the United States as a
matter of law, even if the defendant is a dual citizen of the United States,” and that extradition by
the United Kingdom would be “lengthy” and “uncertain” with bail “very likely” pending the
extradition proceeding. (Tr. 27.) These assertions are incorrect, particularly given Ms.
Maxwell’s irrevocable waiver of her extradition rights with respect to both the United Kingdom
and France.
As we noted for the Court at the initial hearing, the concern that Ms. Maxwell would
attempt to flee the United States is entirely unfounded given that Ms. Maxwell had every motive
and opportunity to flee after the arrest and death of Jeffrey Epstein, but chose to remain in this
attempt to flee the United States is entirely unfounded given that Ms. Maxwell had every motive
and opportunity to flee after the arrest and death of Jeffrey Epstein, but chose to remain in this
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DOJ-OGR-00001127
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