DOJ-OGR-00001136.jpg
499 KB
Extraction Summary
12
People
3
Organizations
14
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal filing / defense memorandum (bail application)
File Size:
499 KB
Summary
This document is page 35 of a legal filing (Document 102) dated December 14, 2020, arguing for Ghislaine Maxwell's release on bail. It contends that her proposed $28.5 million bond package exceeds necessary requirements for ensuring her presence in court. The document features a table comparing Maxwell's proposed bail conditions (including private security and electronic monitoring) to those of other high-profile defendants like Bernie Madoff and Khashoggi, highlighting that her package is stricter than those previously granted release.
People (12)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the bail application; arguing for release from BOP custody to home detention based on a $28.5M bond package.
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| Sadr | Comparative Defendant |
Cited in table: $32.6M bond, Iranian/St Kitts-Nevis citizenship.
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| Dreier | Comparative Defendant |
Cited in table: $10M bond.
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| Madoff | Comparative Defendant |
Cited in table: $10M bond.
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| Khashoggi | Comparative Defendant |
Cited in table: $10M bond, Saudi Arabian citizenship.
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| Esposito | Comparative Defendant |
Cited in table: $9.8M bond.
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| Sabhnani (Wife) | Comparative Defendant |
Cited in table: $2.5M bond, Indonesian citizenship.
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| Sabhnani (Husband) | Comparative Defendant |
Cited in table: $2M bond, Indian citizenship.
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| Bodmer | Comparative Defendant |
Cited in table: $2M bond, Swiss citizenship.
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| Karni | Comparative Defendant |
Cited in table: $7.5M bond, Israel/South Africa citizenship.
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| Hanson | Comparative Defendant |
Cited in table: Bond not reported, connection to China.
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| Hansen | Comparative Defendant |
Cited in table: $500K bond, Danish citizenship.
|
Timeline (2 events)
2020-12-14
Locations (14)
| Location | Context |
|---|---|
|
Proposed location for Maxwell upon release.
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Citizenship location for Sadr.
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Citizenship location for Sadr.
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Citizenship location for Khashoggi.
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Citizenship location for Sabhnani (Wife).
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Citizenship location for Sabhnani (Husband).
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Citizenship location for Bodmer; extradition point for Khashoggi.
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Arrest location for Bodmer.
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Citizenship location for Karni.
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Citizenship location for Karni.
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Citizenship/ties for Hanson.
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Citizenship location for Hansen.
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Citizenship location for Maxwell.
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Citizenship location for Maxwell.
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Relationships (2)
Document argues against government's 'speculative assertions' and burden of proof regarding bail.
Madoff is used as a comparative case in the table to justify Maxwell's release.
Key Quotes (4)
"The Proposed Bail Package Is Expansive and Far Exceeds What Is Necessary to Reasonably Assure Ms. Maxwell’s Presence in Court"Source
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Quote #1
"the government cannot meet its burden to establish that no set of bail conditions would reasonably assure Ms. Maxwell’s appearance in court."Source
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Quote #2
"The proposed bail package is exceptional in its scope... and is more than sufficient to warrant her release from BOP custody"Source
DOJ-OGR-00001136.jpg
Quote #3
"The Court should also not give any weight to the government’s speculative assertions that others might provide money and other support to Ms. Maxwell if she were to flee."Source
DOJ-OGR-00001136.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (2,330 characters)
Case 1:20-cr-00330-AJN Document 102 Filed 12/14/20 Page 35 of 45
F. The Proposed Bail Package Is Expansive and Far Exceeds What Is Necessary to Reasonably Assure Ms. Maxwell’s Presence in Court
In light of the additional information that Ms. Maxwell has provided in connection with this submission, which responds to each of the concerns raised by the government at the initial bail hearing, the government cannot meet its burden to establish that no set of bail conditions would reasonably assure Ms. Maxwell’s appearance in court. The proposed bail package is exceptional in its scope, addresses all of the factors that the Court considered in evaluating risk of flight, and is more than sufficient to warrant her release from BOP custody and transfer to restricted home detention.
Courts in this Circuit have ordered release of high-profile defendants with financial means and foreign citizenship on bonds in lower amounts with less or no security with similar or less restrictive conditions:
[TABLE]
DEFENDANT | BOND | SECURED | HOME DETENTION | ELECTRONIC MONITORING | PRIVATE SECURITY | U.S. CITIZEN | FOREIGN CITIZENSHIP
SADR | $32.6M aggregate | [Check] | Nightly Curfew | [Check] | NO | NO | Iran | St Kitts-Nevis
DREIER | $10M | NO | [Check] | [Check] | [Check] | [Check] | NO
MADOFF | $10M | [Check] | [Check] | [Check] | NO | [Check] | NO
KHASHOGGI Extradited from Switzerland | $10M | [Check] | [Check] | [Check] | NO | [Check] | Saudi Arabia
ESPOSITO | $9.8M | [Check] | [Check] | [Check] | Video Only | [Check] | NO
SABHNANI Wife | $2.5M | [Check] | [Check] | [Check] | NO | [Check] | Indonesia
SABHNANI Husband | $2M | [Check] | [Check] | [Check] | NO | [Check] | India
BODMER Arrested -South Korea | $2M | [Check] | [Check] | [Check] | NO | NO | Switzerland
KARNI No U.S. Ties | $7.5M | [Check] | [Check] | [Check] | NO | NO | Israel | South Africa
HANSON | NOT REPORTED | [Check] | [Check] | [Check] | NO | [Check] | China
HANSEN Travel to Denmark Permitted | $500K | NO | NO | NO | NO | NO | Denmark
MAXWELL | $28.5M aggregate | [Check] | [Check] | [Check] | [Check] | [Check] | UK | France
[END TABLE]
DEFENDANT | BOND | SECURED | HOME DETENTION | ELECTRONIC MONITORING | PRIVATE SECURITY | U.S. CITIZEN | FOREIGN CITIZENSHIP
SADR | $32.6M aggregate | [Check] | Nightly Curfew | [Check] | NO | NO | Iran | St Kitts-Nevis
DREIER | $10M | NO | [Check] | [Check] | [Check] | [Check] | NO
MADOFF | $10M | [Check] | [Check] | [Check] | NO | [Check] | NO
KHASHOGGI Extradited from Switzerland | $10M | [Check] | [Check] | [Check] | NO | [Check] | Saudi Arabia
ESPOSITO | $9.8M | [Check] | [Check] | [Check] | Video Only | [Check] | NO
SABHNANI Wife | $2.5M | [Check] | [Check] | [Check] | NO | [Check] | Indonesia
SABHNANI Husband | $2M | [Check] | [Check] | [Check] | NO | [Check] | India
BODMER Arrested -South Korea | $2M | [Check] | [Check] | [Check] | NO | NO | Switzerland
KARNI No U.S. Ties | $7.5M | [Check] | [Check] | [Check] | NO | NO | Israel | South Africa
HANSON | NOT REPORTED | [Check] | [Check] | [Check] | NO | [Check] | China
HANSEN Travel to Denmark Permitted | $500K | NO | NO | NO | NO | NO | Denmark
MAXWELL | $28.5M aggregate | [Check] | [Check] | [Check] | [Check] | [Check] | UK | France
[END TABLE]
The Court should also not give any weight to the government’s speculative assertions that others might provide money and other support to Ms. Maxwell if she were to flee. (Dkt. 22 at
34
DOJ-OGR-00001136
DOJ-OGR-00001136
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