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601 KB
Extraction Summary
4
People
2
Organizations
0
Locations
3
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal filing (defense motion/memorandum in support of bail)
File Size:
601 KB
Summary
This document is page 2 (filed page 6) of a defense motion filed on December 23, 2020, in the case United States v. Ghislaine Maxwell. The defense argues that the Court should grant bail because the government has conceded its case relies almost exclusively on the testimony of three unidentified witnesses regarding events from over 25 years ago, lacking the 'significant contemporaneous documentary evidence' previously promised. The defense asserts that existing documentary evidence pertains to Jeffrey Epstein rather than Maxwell, though specific government concessions on this point are redacted.
People (4)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
Subject of the bail motion; defense argues the case against her is weak and lacks documentary corroboration.
|
| Jeffrey Epstein | Deceased Sex Offender / Associate |
Mentioned to distinguish evidence; defense argues available documentary evidence pertains to him, not Maxwell.
|
| Three accusers | Witnesses |
Unidentified witnesses whose testimony forms the basis of the government's case.
|
| The Court | Judiciary |
Refers to the judge/court evaluating the bail application.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| The Government |
Opposing party in the case; accused by defense of retreating from claims of having documentary evidence.
|
|
| 8th Cir. |
Cited in case law (1985) regarding the Bail Reform Act.
|
Timeline (3 events)
approx. 1995
Period when alleged events took place (described as 'over 25 years ago')
Unknown
Ms. Maxwell
Accusers
Relationships (2)
Defense argues evidence links to Epstein, not Maxwell: 'pertain to Epstein, not Ms. Maxwell.'
Defense motion arguing against Government's case strength.
Key Quotes (4)
"The legal standard required by the [Bail Reform] Act is one of reasonable assurances, not absolute guarantees."Source
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Quote #1
"The Government Concedes that Its Case Relies Almost Exclusively on the Testimony of Three Witnesses"Source
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Quote #2
"It is abundantly clear from the government’s response that it has no “significant contemporaneous documentary evidence”"Source
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Quote #3
"The few examples of documentary corroboration referenced by the government... pertain to Epstein, not Ms. Maxwell."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (1,942 characters)
Case 1:20-cr-00330-AJN Document 123 Filed 12/23/20 Page 6 of 15
892-93 (8th Cir. 1985) (“The legal standard required by the [Bail Reform] Act is one of reasonable assurances, not absolute guarantees.”). Under, the Bail Reform Act, a defendant must be released unless there are “no conditions” that would reasonably assure her presence. Here, the proposed package satisfies the actual governing standard, and the Court should grant bail.
ARGUMENT
I. The Government Concedes that Its Case Relies Almost Exclusively on the Testimony of Three Witnesses
In evaluating the strength of the government’s case in its prior ruling, the Court relied on the government’s proffer that the testimony of the three accusers would be corroborated by “significant contemporaneous documentary evidence.” (Tr. 82 (emphasis added)). The government now expressly retreats from this position. It is abundantly clear from the government’s response that it has no “significant contemporaneous documentary evidence”—in fact, it has virtually no documentary corroboration at all—and that its case against Ms. Maxwell is based almost exclusively on the recollections of the three accusers, who remain unidentified, concerning events that took place over 25 years ago. Moreover, the government offers no specificity about when within the four-year period of the charged conspiracy the alleged incidents of abuse took place. This, alone, is grounds for the Court to reconsider its prior ruling.
The few examples of documentary corroboration referenced by the government—which are the same examples that the government touted at the initial bail hearing—pertain to Epstein, not Ms. Maxwell. The government concedes that [REDACTED]
[REDACTED]
[REDACTED] (Gov. Mem. at 11 (emphasis added)). The government further states that [REDACTED]
[REDACTED] (Id.
(emphasis added)). The strength of the government’s case against Jeffrey Epstein is not at issue
[REDACTED]
[REDACTED] (Gov. Mem. at 11 (emphasis added)). The government further states that [REDACTED]
[REDACTED] (Id.
(emphasis added)). The strength of the government’s case against Jeffrey Epstein is not at issue
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DOJ-OGR-00020109
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