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695 KB
Extraction Summary
6
People
4
Organizations
1
Locations
4
Events
3
Relationships
5
Quotes
Document Information
Type:
Court filing (defense sentencing memorandum)
File Size:
695 KB
Summary
This document is a page from a defense sentencing memorandum filed on June 15, 2022, arguing that Ghislaine Maxwell should receive sentencing credits for harsh pretrial detention conditions. The text portrays Maxwell as a hardworking humanitarian who helped launch the Clinton Global Initiative and founded TerraMar, while characterizing her relationship with Jeffrey Epstein as a singular mistake resulting from vulnerability caused by her father's death.
People (6)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the sentencing memo; described as hard-working, assisting other inmates, and a victim of a traumatic child...
|
| Jeffrey Epstein | Associate |
Described as the 'biggest mistake' Maxwell made in her life; met him right after her father's death.
|
| Ted Waitt | Associate/Partner |
Mentioned in context of Maxwell trying to protect his children from press vilification.
|
| Maxwell's Father | Family |
Described as overbearing, narcissistic, and demanding; his death made Maxwell vulnerable.
|
| Gonzalez | Legal Citation |
Cited case law regarding pretrial detention credits.
|
| Brissett | Legal Citation |
Cited case law regarding pretrial detention credits.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| MDC |
Metropolitan Detention Center; prison where Maxwell is held and tutoring inmates.
|
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| Clinton Global Initiative |
Organization Maxwell helped launch.
|
|
| TerraMar |
Organization created by Maxwell.
|
|
| DOJ |
Department of Justice (implied by Bates stamp DOJ-OGR-00010482).
|
Timeline (4 events)
Locations (1)
| Location | Context |
|---|---|
|
Detention center where Maxwell is held.
|
Relationships (3)
Described as a mistake she made after her father's death; relationship ended over 15 years prior.
Maxwell tried to protect 'Ted Waitt’s children, her stepchildren'.
Text states she was 'helping launch the Clinton Global Initiative'.
Key Quotes (5)
"Ms. Maxwell should receive a hardship credit in addition to a COVID credit due to the restrictive and harsh conditions of her pretrial detention."Source
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Quote #1
"Ghislaine Maxwell is not an heiress, villain, or vapid socialite."Source
DOJ-OGR-00010482.jpg
Quote #2
"She has endeavored to contribute to society (e.g., by becoming an EMT... helping launch the Clinton Global Initiative, creating TerraMar...)"Source
DOJ-OGR-00010482.jpg
Quote #3
"She has also tried to protect the people around her (Ted Waitt’s children, her stepchildren, the people at TerraMar) from the onslaught of press and public vilification..."Source
DOJ-OGR-00010482.jpg
Quote #4
"It made her vulnerable to Epstein, whom she met right after her father’s death. It is the biggest mistake she made in her life..."Source
DOJ-OGR-00010482.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (2,041 characters)
Case 1:20-cr-00330-PAE Document 663 Filed 06/15/22 Page 36 of 77
supermax detention - involved imprisonment within imprisonment. It was so different from
conventional conditions of pretrial detention as to constitute a different form of hardship and
tantamount to a different form of punishment. Typically, a defendant receives time-served credit
for each day incarcerated prior to sentencing. Pretrial detainees have received and continue to
receive credit beyond time served for detention during COVID. See, e.g., Gonzalez; Brissett,
supra. Ms. Maxwell should receive a hardship credit in addition to a COVID credit due to the
restrictive and harsh conditions of her pretrial detention.
conventional conditions of pretrial detention as to constitute a different form of hardship and
tantamount to a different form of punishment. Typically, a defendant receives time-served credit
for each day incarcerated prior to sentencing. Pretrial detainees have received and continue to
receive credit beyond time served for detention during COVID. See, e.g., Gonzalez; Brissett,
supra. Ms. Maxwell should receive a hardship credit in addition to a COVID credit due to the
restrictive and harsh conditions of her pretrial detention.
CONCLUSION
Ghislaine Maxwell is not an heiress, villain, or vapid socialite. She has worked hard her
entire life. She has energy, drive, commitment, a strong work ethic, and desire to do good in the
world. She has supported friends and family through tough times and personal crisis and currently
is assisting women in her unit at the MDC. She has endeavored to contribute to society (e.g., by
becoming an EMT, developing a platform so that people in remote areas could receive quality
medical assistance, helping launch the Clinton Global Initiative, creating TerraMar, providing
GED tutoring for inmates in her unit) and will continue to do so throughout her sentence and when
she rejoins the community beyond prison walls. She has also tried to protect the people around
her (Ted Waitt’s children, her stepchildren, the people at TerraMar) from the onslaught of press
and public vilification that come with having been associated with her.
entire life. She has energy, drive, commitment, a strong work ethic, and desire to do good in the
world. She has supported friends and family through tough times and personal crisis and currently
is assisting women in her unit at the MDC. She has endeavored to contribute to society (e.g., by
becoming an EMT, developing a platform so that people in remote areas could receive quality
medical assistance, helping launch the Clinton Global Initiative, creating TerraMar, providing
GED tutoring for inmates in her unit) and will continue to do so throughout her sentence and when
she rejoins the community beyond prison walls. She has also tried to protect the people around
her (Ted Waitt’s children, her stepchildren, the people at TerraMar) from the onslaught of press
and public vilification that come with having been associated with her.
She had a difficult, traumatic childhood with an overbearing, narcissistic, and demanding
father. It made her vulnerable to Epstein, whom she met right after her father’s death. It is the
biggest mistake she made in her life and one that she has not and never will repeat. She has never
been accused of anything untoward in the over-15-year period since her relationship with Epstein
father. It made her vulnerable to Epstein, whom she met right after her father’s death. It is the
biggest mistake she made in her life and one that she has not and never will repeat. She has never
been accused of anything untoward in the over-15-year period since her relationship with Epstein
35
DOJ-OGR-00010482
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