DOJ-OGR-00019881.jpg
710 KB
Extraction Summary
3
People
2
Organizations
2
Locations
3
Events
2
Relationships
4
Quotes
Document Information
Type:
Court filing (defense memorandum in support of bail)
File Size:
710 KB
Summary
This document is page 7 of a defense motion filed on July 10, 2020, arguing for Ghislaine Maxwell's release on bail. The defense argues that Maxwell is not a danger to the community (unlike Epstein), that COVID-19 poses a severe health risk in detention hindering her defense, and that she is not a flight risk due to her U.S. citizenship and lack of criminal record. It asserts she stayed in the U.S. and maintained contact with the government after Epstein's arrest rather than fleeing.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the bail request; described as U.S. citizen, resident for 30 years, former head of a non-profit.
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| Jeffrey Epstein | Associate/Comparison |
Mentioned regarding 'supposed ties' and compared against regarding the government's bail position.
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| The Government | Prosecution |
Opposing party in the case; defense argues they have not met burden under Bail Reform Act.
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Organizations (2)
| Name | Type | Context |
|---|---|---|
| Non-profit company |
Unnamed organization run by Maxwell in the US, wound down due to 'media frenzy'.
|
|
| Department of Justice |
Implied by Bates stamp 'DOJ-OGR'.
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Timeline (3 events)
Locations (2)
| Location | Context |
|---|---|
|
Country of residence for Maxwell for almost 30 years.
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Location where Maxwell has family members and friends.
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Relationships (2)
Document mentions 'civil litigation arising from her supposed ties to Epstein'.
Document states she has 'very close ties with family members and friends in New York'.
Key Quotes (4)
"the government does not and cannot assert that Ms. Maxwell presents a danger to the community under Section 3142(g)(4)."Source
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Quote #1
"if Ms. Maxwell continues to be detained, her health will be at serious risk and she will not be able to receive a fair trial."Source
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Quote #2
"She did not flee, but rather left the public eye, for the entirely understandable"Source
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Quote #3
"she ran a non-profit company based in the United States until the recent media frenzy about this case forced her to wind it down"Source
DOJ-OGR-00019881.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (2,067 characters)
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 7 of 28
detention. Importantly, in contrast with the bail position it took with Epstein, the government
does not and cannot assert that Ms. Maxwell presents a danger to the community under Section
3142(g)(4).
does not and cannot assert that Ms. Maxwell presents a danger to the community under Section
3142(g)(4).
Ms. Maxwell’s Response. The Court should exercise its discretion to grant bail to Ms.
Maxwell, on the strict conditions proposed below (or as modified by the Court), for two
compelling reasons.
Maxwell, on the strict conditions proposed below (or as modified by the Court), for two
compelling reasons.
First, the COVID-19 crisis and its impact on detained defendants warrants release. As
this Court has noted, the COVID-19 pandemic represents an unprecedented health risk to
incarcerated individuals, and COVID-19-related restrictions on attorney communications with
pretrial detainees significantly impair a defendant’s ability to prepare her defense. Simply put,
under these circumstances, if Ms. Maxwell continues to be detained, her health will be at serious
risk and she will not be able to receive a fair trial. (See infra Section I, pages 5 to 9).
this Court has noted, the COVID-19 pandemic represents an unprecedented health risk to
incarcerated individuals, and COVID-19-related restrictions on attorney communications with
pretrial detainees significantly impair a defendant’s ability to prepare her defense. Simply put,
under these circumstances, if Ms. Maxwell continues to be detained, her health will be at serious
risk and she will not be able to receive a fair trial. (See infra Section I, pages 5 to 9).
Second, the Court should grant bail because the government has not met its burden under
the Bail Reform Act and controlling case law. The presumption relied on by the government
may be rebutted, and is so here. Ms. Maxwell has strong ties to the community: she is a U.S.
citizen and has lived in this country for almost 30 years; she ran a non-profit company based in
the United States until the recent media frenzy about this case forced her to wind it down to
protect her professional colleagues and their organizations; and she has very close ties with
family members and friends in New York and the rest of the country. Nor does her conduct
indicate that she is a flight risk: she has no prior criminal record; has spent years contesting civil
litigation arising from her supposed ties to Epstein; and has remained in the United States from
the time of Epstein’s arrest until the present, with her counsel in regular contact with the
government. She did not flee, but rather left the public eye, for the entirely understandable
the Bail Reform Act and controlling case law. The presumption relied on by the government
may be rebutted, and is so here. Ms. Maxwell has strong ties to the community: she is a U.S.
citizen and has lived in this country for almost 30 years; she ran a non-profit company based in
the United States until the recent media frenzy about this case forced her to wind it down to
protect her professional colleagues and their organizations; and she has very close ties with
family members and friends in New York and the rest of the country. Nor does her conduct
indicate that she is a flight risk: she has no prior criminal record; has spent years contesting civil
litigation arising from her supposed ties to Epstein; and has remained in the United States from
the time of Epstein’s arrest until the present, with her counsel in regular contact with the
government. She did not flee, but rather left the public eye, for the entirely understandable
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DOJ-OGR-00019881
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