DOJ-OGR-00002782.jpg
581 KB
Extraction Summary
3
People
3
Organizations
1
Locations
2
Events
1
Relationships
5
Quotes
Document Information
Type:
Legal filing (preliminary statement for bail motion)
File Size:
581 KB
Summary
This document is the Preliminary Statement of a legal filing (Document 171) dated March 23, 2021, regarding Ghislaine Maxwell's third application for bail. It outlines a massive proposed bail package including $28.5 million in bonds, $9.5 million in property, renunciation of foreign citizenship, and home confinement in NYC. The filing argues these strict conditions are sufficient to assure her appearance at trial.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant/Applicant |
Subject of the bail application seeking release pending trial.
|
| Unnamed Retired Federal District Court Judge | Asset Monitor |
Proposed to monitor assets as part of bail conditions.
|
| Unnamed Lawyer | Residential Custodian |
One of Maxwell's lawyers (not trial counsel) agreed to reside with her.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Court |
Recipient of the motion (Southern District of New York implied by case number).
|
|
| Unnamed Security Company |
Co-signed a $1M bond.
|
|
| DOJ |
Department of Justice (indicated by footer stamp DOJ-OGR).
|
Timeline (2 events)
2021-03-23
Locations (1)
| Location | Context |
|---|---|
|
Location proposed for home confinement.
|
Relationships (1)
Footnote 2 states 'one of her lawyers... has agreed to reside with her and serve as an additional residential custodian.'
Key Quotes (5)
"The issue before the Court... is whether conditions exist that can reasonably assure Ms. Maxwell's appearance at trial."Source
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Quote #1
"Ms. Maxwell has put before the Court significant enhancements to the already extraordinary bail package"Source
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Quote #2
"unique and comprehensive bail package with the strictest of conditions known in any bail application"Source
DOJ-OGR-00002782.jpg
Quote #3
"Renunciation of British and French citizenship"Source
DOJ-OGR-00002782.jpg
Quote #4
"Irrevocable written waivers of the right to contest extradition"Source
DOJ-OGR-00002782.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (1,789 characters)
Case 1:20-cr-00330-PAE Document 171 Filed 03/23/21 Page 2 of 18
Preliminary Statement
The issue before the Court, as it has been since Ms. Maxwell’s first bail application,
is whether conditions exist that can reasonably assure Ms. Maxwell's appearance at trial.
On her third application (the “Third Bail Motion”) (Dkt. 160), Ms. Maxwell has put before
the Court significant enhancements to the already extraordinary bail package previously
presented to the Court in her renewed application for bail (the “Second Bail Motion”)
(Dkt. 97).¹ Together, these two motions present a unique and comprehensive bail package
with the strictest of conditions known in any bail application:
is whether conditions exist that can reasonably assure Ms. Maxwell's appearance at trial.
On her third application (the “Third Bail Motion”) (Dkt. 160), Ms. Maxwell has put before
the Court significant enhancements to the already extraordinary bail package previously
presented to the Court in her renewed application for bail (the “Second Bail Motion”)
(Dkt. 97).¹ Together, these two motions present a unique and comprehensive bail package
with the strictest of conditions known in any bail application:
▪ $28.5 million in bonds (including a $1M bond co-signed by a security
company);
company);
▪ $9.5 million in real property;
▪ $550,000 in cash;
▪ Asset Monitoring by a retired federal district court judge;
▪ Renunciation of British and French citizenship;
▪ Irrevocable written waivers of the right to contest extradition;
▪ Surrender of all travel documents;
▪ Home confinement in New York City;
▪ Electronic GPS monitoring;
▪ In-residence third-party custodian;²
___________________________________________________________________
¹ Ms. Maxwell’s present motion (the “Third Bail Motion”) (Dkt. 160) incorporates her Memorandum in Support of
Her Renewed Motion for Bail and accompanying exhibits (Dkt. 97, including Attachments 1-24) and her Reply
Memorandum in Support of Her Renewed Motion for Bail (Dkt. 103, including Attachments 1-2) (collectively, the
“Second Bail Motion”).
¹ Ms. Maxwell’s present motion (the “Third Bail Motion”) (Dkt. 160) incorporates her Memorandum in Support of
Her Renewed Motion for Bail and accompanying exhibits (Dkt. 97, including Attachments 1-24) and her Reply
Memorandum in Support of Her Renewed Motion for Bail (Dkt. 103, including Attachments 1-2) (collectively, the
“Second Bail Motion”).
² To assist Ms. Maxwell in making up for lost time preparing for her upcoming trial, one of her lawyers (not trial
counsel) has agreed to reside with her and serve as an additional residential custodian.
counsel) has agreed to reside with her and serve as an additional residential custodian.
1
DOJ-OGR-00002782
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