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511 KB
Extraction Summary
5
People
2
Organizations
2
Locations
2
Events
1
Relationships
5
Quotes
Document Information
Type:
Legal filing / court memorandum (government opposition to bail)
File Size:
511 KB
Summary
This document is page 14 of a government filing (Document 220) from July 13, 2020, in the case against Ghislaine Maxwell (Case 1:20-cr-00330-AJN). The text argues against granting bail, citing the defendant's vast financial resources, lack of ties to the US, and motivation to flee to a non-extradition country. It also specifically argues that the COVID-19 pandemic does not justify her release, citing precedent from other cases in the district.
People (5)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Referenced as 'The defendant' and 'her' throughout the text; subject of the bail opposition in Case 1:20-cr-00330-AJN.
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| Gardephe, J. | Judge |
Cited in reference to United States v. Paulino regarding COVID-19 bail denials.
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| Ramos, J. | Judge |
Cited in reference to United States v. Nunez regarding COVID-19 bail denials.
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| Boustani | Defendant (Cited Case) |
Cited in case law regarding flight risk and financial resources.
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| Zarrab | Defendant (Cited Case) |
Cited in case law regarding flight risk.
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Organizations (2)
| Name | Type | Context |
|---|---|---|
| United States District Court |
S.D.N.Y. (Southern District of New York) and E.D.N.Y. (Eastern District of New York) mentioned in citations.
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| Department of Justice |
Implied by footer 'DOJ-OGR'.
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Locations (2)
| Location | Context |
|---|---|
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Jurisdiction mentioned regarding lack of ties.
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Southern District of New York (Court jurisdiction).
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Relationships (1)
Prosecution arguing against defendant's release in court filing.
Key Quotes (5)
"The defendant’s proposed bail package is essentially nothing more than an unenforceable promise to return to Court."Source
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Quote #1
"Given the gravity of the charged crimes, the defendant’s substantial resources, her willingness to evade detection, and her lies under oath, the Court should take the proposed bail package for what it is worth: nothing."Source
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Quote #2
"The COVID-19 Pandemic Does Not Warrant The Defendant’s Release"Source
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Quote #3
"[B]ecause there is a pandemic does not mean that the jailhouse doors ought to be thrown open"Source
DOJ-OGR-00000998.jpg
Quote #4
"Significantly, the defendant has not claimed that she is at a higher risk from COVID-19"Source
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Quote #5
Full Extracted Text
Complete text extracted from the document (2,070 characters)
Case 1:20-cr-00330-AJN Document 220 Filed 07/13/20 Page 14 of 19
a country that does not extradite its citizens, has access to untold financial resources, and has every motivation to escape accountability for her appalling crimes. See United States v. Boustani, 356 F. Supp. 3d 246, 255 (E.D.N.Y. 2019) (“[T]he combination of Defendant’s alleged deceptive actions, access to substantial financial resources, frequent international travel, complete lack of ties to the United States, and extensive ties to foreign countries without extradition demonstrates Defendant poses a serious risk of flight.”) (citing United States v. Zarrab, No. 15 Cr. 867 (RMB), 2016 WL 3681423, at *8 (S.D.N.Y. June 16, 2016)). The defendant’s proposed bail package is essentially nothing more than an unenforceable promise to return to Court. Given the gravity of the charged crimes, the defendant’s substantial resources, her willingness to evade detection, and her lies under oath, the Court should take the proposed bail package for what it is worth: nothing.
V. The COVID-19 Pandemic Does Not Warrant The Defendant’s Release
Finally, the current pandemic is not a reason to release this defendant. Indeed, courts in this district have regularly rejected applications for release based on assertions about the generalized risks of COVID-19. See, e.g., United States v. Paulino, No. 19 Cr. 54 (PGG), 2020 WL 1847914, at *6 (S.D.N.Y. Apr. 13, 2020) (Gardephe, J.) (denying bail application by defendant with hypertension, stating that “[a]s serious as it is, the outbreak of COVID-19 simply does not override the statutory detention provisions [of the Bail Reform Act]” (internal quotation omitted)); United States v. Ortiz, 19 Cr. 198 (KPF), 2020 WL 2539124, at *2 (S.D.N.Y. May 19, 2020) (quoting United States v. Nunez, No. 20 Cr. 239 (ER) (S.D.N.Y. Apr. 10, 2020) (Ramos, J.) (“[B]ecause there is a pandemic does not mean that the jailhouse doors ought to be thrown open”)). Significantly, the defendant has not claimed that she is at a higher risk from COVID-19
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DOJ-OGR-00000998
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