DOJ-OGR-00001586.jpg
730 KB
Extraction Summary
4
People
3
Organizations
3
Locations
3
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal filing (defense memorandum/court document)
File Size:
730 KB
Summary
This document is page 2 (labeled page 6 of 26 in the filing) of a legal defense filing arguing against the detention of Ghislaine Maxwell. It outlines her background, emphasizing her US citizenship, long-term residency, and strong family ties to counter the government's argument that she is a flight risk. It also summarizes the government's position regarding her multiple citizenships and financial means, while refuting the claim that she was 'hiding' from law enforcement.
People (4)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the bail hearing; described as 58-year-old naturalized U.S. citizen with triple citizenship (US, UK, France).
|
| Jeffrey Epstein | Co-conspirator/Associate |
Mentioned in relation to his July 2019 indictment and subsequent arrest.
|
| Siblings of Ghislaine Maxwell | Family |
Six siblings mentioned as having extremely close relationships with her.
|
| Nieces and Nephews of Ghislaine Maxwell | Family |
Mentioned as supportive family members living in the US.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| United States District Court |
Implied by case number Case 1:20-cr-00330-AJN.
|
|
| Oxford University |
Institution where Ms. Maxwell graduated.
|
|
| Department of Justice (DOJ) |
Indicated by footer stamp DOJ-OGR-00001586 and references to 'The Government'.
|
Timeline (3 events)
Locations (3)
| Location | Context |
|---|---|
|
Maxwell's residence since 1991; residence of two sisters and their children.
|
|
|
Maxwell's place of birth and country of citizenship.
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|
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Place of Maxwell's education, childhood, and citizenship.
|
Relationships (2)
Referenced in context of his indictment and arrest.
She is a godmother to many of her friends' children.
Key Quotes (4)
"Ms. Maxwell, 58, is a naturalized U.S. citizen who has resided in the United States since 1991."Source
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Quote #1
"Ms. Maxwell has maintained extremely close relationships with her six siblings and her nephews and nieces."Source
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Quote #2
"They all stood by her in the aftermath of the July 2019 indictment of Epstein and continue to stand by her now."Source
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Quote #3
"the government speculates that Ms. Maxwell was 'hiding' from law enforcement during the pendency of the investigation, even though she has been in regular contact with the government, through counsel, since Epstein’s arrest."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,131 characters)
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 6 of 26
Background. Ms. Maxwell, 58, is a naturalized U.S. citizen who has resided in the
United States since 1991. She is also a citizen of France, where she was born, and of the United
Kingdom, where she was educated and spent her childhood and formative years. Ms. Maxwell
graduated from Oxford University. She moved to the United States in 1991, and has lived in this
country ever since that time. Ms. Maxwell has maintained extremely close relationships with her
six siblings and her nephews and nieces. They all stood by her in the aftermath of the July 2019
indictment of Epstein and continue to stand by her now. She is especially close to two of her
sisters and their children, all of whom reside in the United States. Ms. Maxwell also has
numerous friends in the United States who themselves have children, and she is a godmother to
many of them. Ms. Maxwell’s family and friends have remained committed to her because they
do not believe the allegations against her, which do not match the person they have known for
decades.
United States since 1991. She is also a citizen of France, where she was born, and of the United
Kingdom, where she was educated and spent her childhood and formative years. Ms. Maxwell
graduated from Oxford University. She moved to the United States in 1991, and has lived in this
country ever since that time. Ms. Maxwell has maintained extremely close relationships with her
six siblings and her nephews and nieces. They all stood by her in the aftermath of the July 2019
indictment of Epstein and continue to stand by her now. She is especially close to two of her
sisters and their children, all of whom reside in the United States. Ms. Maxwell also has
numerous friends in the United States who themselves have children, and she is a godmother to
many of them. Ms. Maxwell’s family and friends have remained committed to her because they
do not believe the allegations against her, which do not match the person they have known for
decades.
The Government’s Position. The government has the burden of persuasion in showing
that detention is warranted, and that there are no conditions or combination of conditions that
will secure a defendant’s appearance in court. In seeking to carry this burden, the government
relies on the presumption of detention in 18 U.S.C. § 3142(e)(3)(E), and argues that Ms.
Maxwell poses a flight risk because she supposedly lacks ties to the United States; is a citizen of
the United Kingdom and France, as well as a citizen of the United States, and has passports for
each country; has traveled internationally in the past; and has financial means. And echoing
recent media stories, the government speculates that Ms. Maxwell was “hiding” from law
enforcement during the pendency of the investigation, even though she has been in regular
contact with the government, through counsel, since Epstein’s arrest. Finally, the government
argues that the nature and circumstances of the offense and the weight of the evidence warrant
that detention is warranted, and that there are no conditions or combination of conditions that
will secure a defendant’s appearance in court. In seeking to carry this burden, the government
relies on the presumption of detention in 18 U.S.C. § 3142(e)(3)(E), and argues that Ms.
Maxwell poses a flight risk because she supposedly lacks ties to the United States; is a citizen of
the United Kingdom and France, as well as a citizen of the United States, and has passports for
each country; has traveled internationally in the past; and has financial means. And echoing
recent media stories, the government speculates that Ms. Maxwell was “hiding” from law
enforcement during the pendency of the investigation, even though she has been in regular
contact with the government, through counsel, since Epstein’s arrest. Finally, the government
argues that the nature and circumstances of the offense and the weight of the evidence warrant
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DOJ-OGR-00001586
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