DOJ-OGR-00002013.jpg
737 KB
Extraction Summary
3
People
4
Organizations
2
Locations
3
Events
1
Relationships
6
Quotes
Document Information
Type:
Court filing / legal motion (defense brief regarding bail)
File Size:
737 KB
Summary
This document is page 35 (filed as page 41 of 45) of a legal motion arguing for Ghislaine Maxwell's release on bail. The defense argues that Maxwell is not a flight risk and that her current detention at the MDC amounts to 'de facto solitary confinement' under conditions more severe than supermax prisons or death row, which impedes her ability to prepare her defense. The text cites legal precedent regarding bail standards and claims wardens have never seen such restrictive regulations.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the bail application; arguing against current detention conditions.
|
| Jeffrey Epstein | Deceased Associate |
Mentioned in relation to the timeline of events ('since Epstein's arrest').
|
| Wardens / Interim Wardens | Prison Officials |
Unnamed officials cited as remarking they have never seen a regime like Maxwell's.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| MDC |
Metropolitan Detention Center; facility where Maxwell is detained.
|
|
| USP Florence ADMAX |
Federal supermax prison; used as a comparison for the severity of Maxwell's conditions.
|
|
| Department of Justice (DOJ) |
Indicated by the Bates stamp 'DOJ-OGR'.
|
|
| 8th Circuit Court |
Cited in legal precedent (United States v. Orta).
|
Timeline (3 events)
Pre-Dec 2020 (approx. 5 months prior)
Locations (2)
| Location | Context |
|---|---|
|
Detention center where Maxwell is held.
|
|
|
Colorado supermax prison (cited for comparison).
|
Relationships (1)
Reference to 'since Epstein's arrest' as a timeline marker for her family's struggles.
Key Quotes (6)
"Ms. Maxwell is not obligated to rebut every theoretical possibility that the government might raise that may contribute to a potential flight risk in order to be granted bail."Source
DOJ-OGR-00002013.jpg
Quote #1
"Ms. Maxwell has no intention of fleeing. If she did, then under the proposed bail conditions she would lose everything and destroy the family she has been fighting so hard to protect since Epstein’s arrest."Source
DOJ-OGR-00002013.jpg
Quote #2
"The alternative to release is her continued confinement under extraordinarily onerous conditions that are not only unjust and punitive, but also meaningfully impair Ms. Maxwell’s ability to review the voluminous discovery"Source
DOJ-OGR-00002013.jpg
Quote #3
"Ms. Maxwell has spent the entirety of her detention—now over five months—in de facto solitary confinement"Source
DOJ-OGR-00002013.jpg
Quote #4
"conditions that rival those used at USP Florence ADMAX to supervise the most dangerous inmates in the federal system"Source
DOJ-OGR-00002013.jpg
Quote #5
"tantamount to imprisonment as a defendant convicted of capital murder and incarcerated on death row."Source
DOJ-OGR-00002013.jpg
Quote #6
Full Extracted Text
Complete text extracted from the document (2,156 characters)
Case 1:20-cr-00330-AJN Document 97 Filed 12/14/20 Page 41 of 45
11-12). Ms. Maxwell is not obligated to rebut every theoretical possibility that the government
might raise that may contribute to a potential flight risk in order to be granted bail. That is not
the standard. Cf. United States v. Orta, 760 F.2d 887, 888 n.4, 892-93 (8th Cir. 1985) (“The
legal standard required by the [Bail Reform] Act is one of reasonable assurances, not absolute
guarantees.”). Ms. Maxwell has no intention of fleeing. If she did, then under the proposed bail
conditions she would lose everything and destroy the family she has been fighting so hard to
protect since Epstein’s arrest. Ms. Maxwell will not do that, and should be granted bail.
might raise that may contribute to a potential flight risk in order to be granted bail. That is not
the standard. Cf. United States v. Orta, 760 F.2d 887, 888 n.4, 892-93 (8th Cir. 1985) (“The
legal standard required by the [Bail Reform] Act is one of reasonable assurances, not absolute
guarantees.”). Ms. Maxwell has no intention of fleeing. If she did, then under the proposed bail
conditions she would lose everything and destroy the family she has been fighting so hard to
protect since Epstein’s arrest. Ms. Maxwell will not do that, and should be granted bail.
G. The Alternative to Bail Is Confinement Under Oppressive Conditions
that Impact Ms. Maxwell’s Health and Ability to Prepare Her Defense
that Impact Ms. Maxwell’s Health and Ability to Prepare Her Defense
Granting bail to Ms. Maxwell is all the more appropriate and necessary because the past
few months have shown that Ms. Maxwell cannot adequately participate in her defense and
prepare for trial from the inside the MDC. The alternative to release is her continued
confinement under extraordinarily onerous conditions that are not only unjust and punitive, but
also meaningfully impair Ms. Maxwell’s ability to review the voluminous discovery produced by
the government and to communicate effectively with counsel to prepare her defense.
few months have shown that Ms. Maxwell cannot adequately participate in her defense and
prepare for trial from the inside the MDC. The alternative to release is her continued
confinement under extraordinarily onerous conditions that are not only unjust and punitive, but
also meaningfully impair Ms. Maxwell’s ability to review the voluminous discovery produced by
the government and to communicate effectively with counsel to prepare her defense.
Ms. Maxwell has spent the entirety of her detention—now over five months—in de facto
solitary confinement, under conditions that rival those used at USP Florence ADMAX to
supervise the most dangerous inmates in the federal system and are tantamount to imprisonment
as a defendant convicted of capital murder and incarcerated on death row. In fact, multiple
wardens and interim wardens have remarked that in their collective years of experience they
have never seen anything like her current regime. The restrictive regulations to which Ms.
Maxwell is subjected are not reasonably related to a legitimate goal to ensure the security of Ms.
Maxwell or the MDC. Instead, it seems clear that the overly restrictive conditions are an
solitary confinement, under conditions that rival those used at USP Florence ADMAX to
supervise the most dangerous inmates in the federal system and are tantamount to imprisonment
as a defendant convicted of capital murder and incarcerated on death row. In fact, multiple
wardens and interim wardens have remarked that in their collective years of experience they
have never seen anything like her current regime. The restrictive regulations to which Ms.
Maxwell is subjected are not reasonably related to a legitimate goal to ensure the security of Ms.
Maxwell or the MDC. Instead, it seems clear that the overly restrictive conditions are an
35
DOJ-OGR-00002013
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document