DOJ-OGR-00001146.jpg
643 KB
Extraction Summary
2
People
3
Organizations
1
Locations
3
Events
1
Relationships
3
Quotes
Document Information
Type:
Court filing (government memorandum in opposition)
File Size:
643 KB
Summary
This document is the first page of the Government's Memorandum in Opposition to Ghislaine Maxwell's renewed motion for release on bail, filed on December 18, 2020. The Government argues that the Court's previous July 2020 ruling—that Maxwell poses a serious flight risk and has extensive financial resources/foreign ties—remains correct and should not be reversed. The prosecution asserts that the new motion merely repackages prior arguments and that no combination of conditions can ensure her appearance in court.
People (2)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the bail motion; described as posing a serious flight risk with extensive financial resources and foreign ...
|
| AJN | Judge |
Initials appearing in the case number (20 Cr. 330 (AJN)), referring to Judge Alison J. Nathan.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| United States District Court Southern District of New York |
Venue of the legal proceedings.
|
|
| United States of America |
The Government opposing the defendant's release.
|
|
| DOJ |
Department of Justice, implied by the bates stamp prefix DOJ-OGR.
|
Timeline (3 events)
2020-07-14
Bail hearing where the Court concluded the defendant posed a serious flight risk.
Southern District of New York
2020-12-08
Defendant filed a renewed motion for release on bail.
Southern District of New York
2020-12-18
Filing of the Government's Memorandum in Opposition.
Southern District of New York
The Government
Locations (1)
| Location | Context |
|---|---|
|
Jurisdiction of the court.
|
Relationships (1)
Case caption: United States of America -v.- Ghislaine Maxwell
Key Quotes (3)
"this Court concluded that the defendant posed a serious flight risk and that no condition or combination of conditions could ensure her appearance in court."Source
DOJ-OGR-00001146.jpg
Quote #1
"The Court’s conclusion was plainly correct, and the Renewed Bail Motion does nothing to undermine it."Source
DOJ-OGR-00001146.jpg
Quote #2
"the defendant continues to have extensive financial resources and foreign ties"Source
DOJ-OGR-00001146.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,764 characters)
Case 1:20-cr-00330-AJN Document 102 Filed 12/18/20 Page 1 of 36
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
--------------------------------------------------------------x
UNITED STATES OF AMERICA
:
-v.- :
20 Cr. 330 (AJN)
GHISLAINE MAXWELL,
:
Defendant.
:
--------------------------------------------------------------x
SOUTHERN DISTRICT OF NEW YORK
--------------------------------------------------------------x
UNITED STATES OF AMERICA
:
-v.- :
20 Cr. 330 (AJN)
GHISLAINE MAXWELL,
:
Defendant.
:
--------------------------------------------------------------x
THE GOVERNMENT’S MEMORANDUM IN OPPOSITION TO THE DEFENDANT’S
RENEWED MOTION FOR RELEASE
RENEWED MOTION FOR RELEASE
The Government respectfully submits this memorandum in opposition to the defendant’s
renewed motion for release on bail, dated December 8, 2020 (the “Renewed Bail Motion”). Five
months ago, after thorough briefing and a nearly two-hour hearing, this Court concluded that the
defendant posed a serious flight risk and that no condition or combination of conditions could
ensure her appearance in court. The defense now asks this Court to reverse that finding by
essentially repackaging its prior arguments and presenting a more specific bail package. However,
at the July 14, 2020 bail hearing in this case, this Court rejected the defendant’s request to keep
the record open to allow the defendant to do precisely what she has done here—namely, present
more detailed information about her finances and a more concrete package—determining that
further information about her financial picture would be irrelevant because no combination of
conditions could ensure this defendant’s appearance. The Court’s conclusion was plainly correct,
and the Renewed Bail Motion does nothing to undermine it. The offense conduct outlined in the
Indictment remains incredibly serious, the evidence against the defendant remains strong, and the
defendant continues to have extensive financial resources and foreign ties, as well as the
renewed motion for release on bail, dated December 8, 2020 (the “Renewed Bail Motion”). Five
months ago, after thorough briefing and a nearly two-hour hearing, this Court concluded that the
defendant posed a serious flight risk and that no condition or combination of conditions could
ensure her appearance in court. The defense now asks this Court to reverse that finding by
essentially repackaging its prior arguments and presenting a more specific bail package. However,
at the July 14, 2020 bail hearing in this case, this Court rejected the defendant’s request to keep
the record open to allow the defendant to do precisely what she has done here—namely, present
more detailed information about her finances and a more concrete package—determining that
further information about her financial picture would be irrelevant because no combination of
conditions could ensure this defendant’s appearance. The Court’s conclusion was plainly correct,
and the Renewed Bail Motion does nothing to undermine it. The offense conduct outlined in the
Indictment remains incredibly serious, the evidence against the defendant remains strong, and the
defendant continues to have extensive financial resources and foreign ties, as well as the
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DOJ-OGR-00001146
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