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768 KB
Extraction Summary
11
People
4
Organizations
3
Locations
1
Events
1
Relationships
4
Quotes
Document Information
Type:
Court filing (legal brief/memorandum)
File Size:
768 KB
Summary
This document is page 17 of a court filing (Document 22) in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on July 13, 2020. The text argues against granting bail, citing an 'extraordinary risk of flight' and rejecting the defendant's claim that detention at the MDC prevents adequate preparation for defense. The filing cites numerous precedents (Tolentino, Adamu, Brito, etc.) where bail was denied despite access-to-counsel restrictions, distinguishing the current case from *United States v. Stephens*.
People (11)
| Name | Role | Context |
|---|---|---|
| The Defendant | Defendant |
Subject of the bail hearing, referred to as 'her', facing 'extraordinary risk of flight'. (Contextually Ghislaine Max...
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| AJN | Judge |
Presiding Judge identified in case number 1:20-cr-00330-AJN (Alison J. Nathan).
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| Tolentino | Defendant (Case Law) |
Cited in United States v. Tolentino regarding bail denial.
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| Adamu | Defendant (Case Law) |
Cited in United States v. Adamu regarding bail denial.
|
| Brito | Defendant (Case Law) |
Cited in United States v. Brito regarding bail denial.
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| Ellison | Defendant (Case Law) |
Cited in United States v. Ellison regarding bail denial.
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| Melamed | Defendant (Case Law) |
Cited in United States v. Melamed regarding bail denial.
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| Pena | Defendant (Case Law) |
Cited in United States v. Pena regarding bail denial.
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| Shipp | Defendant (Case Law) |
Cited in United States v. Shipp regarding bail denial.
|
| Stephens | Defendant (Case Law) |
Cited in United States v. Stephens where bail was granted for a specific hearing.
|
| Gonzalez | Defendant (Case Law) |
Cited in United States v. Gonzalez.
|
Timeline (1 events)
Locations (3)
| Location | Context |
|---|---|
|
Jurisdiction where the case is being heard
|
|
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Neighboring jurisdiction cited for case law
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|
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Detention center where access to counsel is discussed
|
Relationships (1)
Defendant is applying for bail; Court is reviewing arguments.
Key Quotes (4)
"The defendant’s argument that bail is required for her to prepare her defense is equally unpersuasive."Source
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Quote #1
"Judges in this district have repeatedly held that the current restrictions on inmate access to counsel do not warrant releasing defendants who should otherwise be detained under the Bail Reform Act."Source
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Quote #2
"This Court should reach the same conclusion based on the extraordinary risk of flight described in detail above."Source
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Quote #3
"By contrast, no evidentiary hearings have been requested, much less scheduled, in this case, and a trial date has not yet been set."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,263 characters)
Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 17 of 19
applications in view of the applicable factors under the Bail Reform Act. This Court should reach
the same conclusion based on the extraordinary risk of flight described in detail above.
the same conclusion based on the extraordinary risk of flight described in detail above.
The defendant’s argument that bail is required for her to prepare her defense is equally
unpersuasive. Judges in this district have repeatedly held that the current restrictions on inmate
access to counsel do not warrant releasing defendants who should otherwise be detained under the
Bail Reform Act. See United States v. Tolentino, 20 Cr. 007 (DLC), 2020 WL 1862670, at *2
(S.D.N.Y. Apr. 14, 2020); United States v. Adamu, 18 Cr. 601 (PGG), 2020 WL 1821717, at *6
(Apr. 10, 2020); United States v. Brito, 20 Cr. 63 (PGG), 2020 WL 2521458, at *5-6 (S.D.N.Y.
May 17, 2020); United States v. Ellison, 18 Cr. 834 (PAE), 2020 WL 1989301, at *1-2 (S.D.N.Y.
Apr. 27), United States v. Melamed, No. 19 Cr. 443 (LAK), 2020 WL 1644205, at *2 (S.D.N.Y.
Apr. 2, 2020); United States v. Pena, No. 18 Cr. 640 (RA), 2020 WL 1674007, at *1 (S.D.N.Y.
Apr. 6, 2020). Just last week, a district judge in the Eastern District of New York denied bail to a
defendant who argued that restricted access to his counsel at the MDC required his release, while
noting the volume of decisions reaching the same conclusion. United States v. Shipp, No. 19 Cr.
299 (NGG), 2020 WL 3642856, *3-4 (E.D.N.Y. July 6, 2020) (collecting cases).
unpersuasive. Judges in this district have repeatedly held that the current restrictions on inmate
access to counsel do not warrant releasing defendants who should otherwise be detained under the
Bail Reform Act. See United States v. Tolentino, 20 Cr. 007 (DLC), 2020 WL 1862670, at *2
(S.D.N.Y. Apr. 14, 2020); United States v. Adamu, 18 Cr. 601 (PGG), 2020 WL 1821717, at *6
(Apr. 10, 2020); United States v. Brito, 20 Cr. 63 (PGG), 2020 WL 2521458, at *5-6 (S.D.N.Y.
May 17, 2020); United States v. Ellison, 18 Cr. 834 (PAE), 2020 WL 1989301, at *1-2 (S.D.N.Y.
Apr. 27), United States v. Melamed, No. 19 Cr. 443 (LAK), 2020 WL 1644205, at *2 (S.D.N.Y.
Apr. 2, 2020); United States v. Pena, No. 18 Cr. 640 (RA), 2020 WL 1674007, at *1 (S.D.N.Y.
Apr. 6, 2020). Just last week, a district judge in the Eastern District of New York denied bail to a
defendant who argued that restricted access to his counsel at the MDC required his release, while
noting the volume of decisions reaching the same conclusion. United States v. Shipp, No. 19 Cr.
299 (NGG), 2020 WL 3642856, *3-4 (E.D.N.Y. July 6, 2020) (collecting cases).
This Court’s decision in Stephens does not compel a different result here. In that case, this
Court concluded that bail was necessary in order to permit the defendant to prepare for a significant
hearing, which was scheduled for six days later. United States v. Stephens, No. 15 Cr. 95 (AJN),
2020 WL 1295155, at *3 (S.D.N.Y. Mar. 19, 2020) (finding that the limitations on the defendant’s
access to counsel “impacts the Defendant’s ability to prepare his defenses to the alleged violation
of supervised release in advance of the merits hearing scheduled for March 25, 2020.”). By
contrast, no evidentiary hearings have been requested, much less scheduled, in this case, and a trial
date has not yet been set. See United States v. Gonzalez, No. 19 Cr. 906 (JMF), 2020 WL 1911209,
Court concluded that bail was necessary in order to permit the defendant to prepare for a significant
hearing, which was scheduled for six days later. United States v. Stephens, No. 15 Cr. 95 (AJN),
2020 WL 1295155, at *3 (S.D.N.Y. Mar. 19, 2020) (finding that the limitations on the defendant’s
access to counsel “impacts the Defendant’s ability to prepare his defenses to the alleged violation
of supervised release in advance of the merits hearing scheduled for March 25, 2020.”). By
contrast, no evidentiary hearings have been requested, much less scheduled, in this case, and a trial
date has not yet been set. See United States v. Gonzalez, No. 19 Cr. 906 (JMF), 2020 WL 1911209,
16
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