DOJ-OGR-00019870.jpg
526 KB
Extraction Summary
3
People
4
Organizations
5
Locations
2
Events
0
Relationships
4
Quotes
Document Information
Type:
Court filing (government memorandum in support of detention)
File Size:
526 KB
Summary
This document is page 6 of a court filing (Case 1:20-cr-00330-AJN) arguing for the detention of the defendant (Ghislaine Maxwell). The text outlines her flight risk due to her 'extensive international ties,' noting she holds citizenship and passports for the US, UK, and France. It cites CBP records showing frequent travel, including 15 international flights in the prior three years to locations like Japan and Qatar.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Referred to as 'the defendant' and 'she'. Described as having extensive international ties, born in France, raised in...
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| Chief | Case Subject |
Referenced in case citation United States v. Chief
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| Pierre-Louis | Case Subject |
Referenced in case citation United States v. Pierre-Louis
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Organizations (4)
| Name | Type | Context |
|---|---|---|
| United States Customs and Border Protection |
Provided travel records (CBP) reflecting the defendant's movements.
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| Department of Justice |
Indicated by footer 'DOJ-OGR'
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| 9th Circuit Court of Appeals |
Cited in legal precedent.
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| S.D.N.Y. |
Southern District of New York, cited in legal precedent.
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Locations (5)
| Location | Context |
|---|---|
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Defendant's birthplace and country of citizenship.
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Place where defendant was raised, attended school, holds citizenship, and traveled to.
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Country of naturalized citizenship (2002) and passport issuance.
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Travel destination in the last three years.
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Travel destination in the last three years.
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Key Quotes (4)
"the defendant’s extensive international ties would make it exceptionally easy for her to flee and live abroad."Source
DOJ-OGR-00019870.jpg
Quote #1
"the defendant has the means and money to do so."Source
DOJ-OGR-00019870.jpg
Quote #2
"she also remains a citizen of the United Kingdom and France."Source
DOJ-OGR-00019870.jpg
Quote #3
"CBP records reflect that... the defendant appears to possess passports from the United States, France, and the United Kingdom."Source
DOJ-OGR-00019870.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (2,186 characters)
Case 1:20-cr-00330-AJN Document 24 Filed 07/02/20 Page 6 of 20
date of the amendment,¹ to permit a prosecution at any point during the lifetime of the minor
victim. See United States v. Chief, 438 F.3d 920, 922-25 (9th Cir. 2006) (finding that because
Congress extended the statute of limitations for sex offenses involving minors during the time the
previous statute was still running, the extension was permissible); United States v. Pierre-Louis,
No. 16 Cr. 541 (CM), 2018 WL 4043140, at *1 (S.D.N.Y. Aug. 9, 2018) (same). Moreover, while
the conduct alleged in the Indictment may have occurred years ago, the risk of a significant term
of incarceration – and thus the motive to flee – is of course only very recent.
victim. See United States v. Chief, 438 F.3d 920, 922-25 (9th Cir. 2006) (finding that because
Congress extended the statute of limitations for sex offenses involving minors during the time the
previous statute was still running, the extension was permissible); United States v. Pierre-Louis,
No. 16 Cr. 541 (CM), 2018 WL 4043140, at *1 (S.D.N.Y. Aug. 9, 2018) (same). Moreover, while
the conduct alleged in the Indictment may have occurred years ago, the risk of a significant term
of incarceration – and thus the motive to flee – is of course only very recent.
Each of these factors – the seriousness of the allegations, the strength of the evidence, and
the possibility of lengthy incarceration – creates an extraordinary incentive to flee. And as further
described below, the defendant has the means and money to do so.
the possibility of lengthy incarceration – creates an extraordinary incentive to flee. And as further
described below, the defendant has the means and money to do so.
B. The Characteristics of the Defendant
The history and characteristics of the defendant also strongly support detention. As an
initial matter, the defendant’s extensive international ties would make it exceptionally easy for her
to flee and live abroad. The defendant was born in France and raised in the United Kingdom,
where she attended school. Although she became a naturalized citizen of the United States in
2002, she also remains a citizen of the United Kingdom and France. Travel records from
United States Customs and Border Protection (“CBP”) reflect that she has engaged in frequent
international travel, including at least fifteen international flights in the last three years to locations
including the United Kingdom, Japan, and Qatar. In addition, CBP records reflect that, consistent
with her citizenship status, the defendant appears to possess passports from the United States,
France, and the United Kingdom.
initial matter, the defendant’s extensive international ties would make it exceptionally easy for her
to flee and live abroad. The defendant was born in France and raised in the United Kingdom,
where she attended school. Although she became a naturalized citizen of the United States in
2002, she also remains a citizen of the United Kingdom and France. Travel records from
United States Customs and Border Protection (“CBP”) reflect that she has engaged in frequent
international travel, including at least fifteen international flights in the last three years to locations
including the United Kingdom, Japan, and Qatar. In addition, CBP records reflect that, consistent
with her citizenship status, the defendant appears to possess passports from the United States,
France, and the United Kingdom.
¹ Prior to the amendment, the statute of limitations for sexual offenses involving minors ran until
the victim reached the age of 25, and as such, all of the relevant charges in the Indictment
remained timely as of the 2003 amendment described above.
the victim reached the age of 25, and as such, all of the relevant charges in the Indictment
remained timely as of the 2003 amendment described above.
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DOJ-OGR-00019870
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