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736 KB

Extraction Summary

4
People
5
Organizations
2
Locations
3
Events
3
Relationships
5
Quotes

Document Information

Type: Court filing (legal brief/motion)
File Size: 736 KB
Summary

This document is a page from a legal filing (Motion for Bail) arguing that Ghislaine Maxwell has now provided a thorough review of her finances for the years 2015-2020, addressing previous court concerns. Defense counsel retained UK accounting firm Macalvins to analyze bank statements, tax returns, and FBAR filings for Maxwell and her spouse. This report was further validated by a redacted former IRS Special Agent with 40 years of experience in financial fraud.

People (4)

Name Role Context
Ghislaine Maxwell Defendant
Subject of the bail hearing and financial review; detained following arrest.
Ms. Maxwell's Spouse Family/Associate
Mentioned as holding assets jointly or alongside Maxwell.
[REDACTED] Expert Witness/Consultant
Certified Fraud Examiner and former IRS Special Agent with 40+ years experience; reviewed the Macalvins report.
Defense Counsel Legal Representative
Retained Macalvins to analyze Maxwell's finances.

Organizations (5)

Name Type Context
Macalvins
Accounting firm in the United Kingdom retained by defense counsel.
Pretrial Services
Government agency that received initial financial disclosures.
IRS
Internal Revenue Service; former employer of the redacted expert witness.
The Court
Judicial body requesting financial clarity.
The Government
Prosecution; raised concerns about initial disclosures.

Timeline (3 events)

2015-2020
Period covered by the financial analysis performed by Macalvins
United Kingdom / Global
2020-12-14
Filing of Document 97 in Case 1:20-cr-00330-AJN
Court
Prior to 2020-12-14
Initial bail hearing where government raised concerns about financial disclosures
Court

Locations (2)

Location Context
Location of the accounting firm Macalvins.
Likely SDNY, where the redacted agent investigated cases.

Relationships (3)

Ghislaine Maxwell Client/Service Provider Macalvins
Defense counsel retained Macalvins... to conduct an analysis of Ms. Maxwell’s assets
Ghislaine Maxwell Spousal/Financial Ms. Maxwell's Spouse
assets held by Ms. Maxwell and her spouse
Macalvins Reviewer/Subject [REDACTED]
The Macalvins report was also reviewed by [REDACTED]

Key Quotes (5)

"The Court stated that it did not have 'a clear picture of Ms. Maxwell's finances and the resources available to her'"
Source
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Quote #1
"therefore had no way 'to set financial bail conditions that could reasonably assure her appearance in court.'"
Source
DOJ-OGR-00001993.jpg
Quote #2
"defense counsel retained Macalvins, a highly reputable accounting firm in the United Kingdom"
Source
DOJ-OGR-00001993.jpg
Quote #3
"create a clear picture of the assets held by Ms. Maxwell and her spouse"
Source
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Quote #4
"The Macalvins report was also reviewed by [REDACTED], a Certified Fraud Examiner and a former IRS Special Agent with over 40 years of experience"
Source
DOJ-OGR-00001993.jpg
Quote #5

Full Extracted Text

Complete text extracted from the document (2,143 characters)

Case 1:20-cr-00330-AJN Document 97 Filed 12/14/20 Page 21 of 45
B. Ms. Maxwell Has Provided a Thorough Review of Her Finances for the Past Five Years
The government raised concerns at the initial bail hearing about the accuracy and completeness of the financial disclosures that Ms. Maxwell provided to Pretrial Services. (Dkt. 22 at 11-12; Tr. 28-29, 34-35). The Court stated that it did not have “a clear picture of Ms. Maxwell's finances and the resources available to her” and therefore had no way “to set financial bail conditions that could reasonably assure her appearance in court.” (Tr. 86-87).
To address the Court’s questions about Ms. Maxwell’s finances, defense counsel retained Macalvins, a highly reputable accounting firm in the United Kingdom, to conduct an analysis of Ms. Maxwell’s assets and finances for the past five years. The Macalvins accountants reviewed thousands of pages of financial documents, including bank statements, tax returns, FBAR filings, and other materials to create a clear picture of the assets held by Ms. Maxwell and her spouse, as well as any assets held in trust for the benefit of Ms. Maxwell, and the source of those assets from 2015-2020. This analysis, which is based in substantial part on documents that the government provided in discovery, has involved a significant amount of work and has taken substantial time to complete. It was not possible to perform this analysis in the brief time between Ms. Maxwell’s arrest and the initial bail hearing, especially with Ms. Maxwell detained following her arrest.
The Macalvins report was also reviewed by [REDACTED], a Certified Fraud Examiner and a former IRS Special Agent with over 40 years of experience in complex financial fraud investigations. As a Special Agent, [REDACTED] investigated numerous financial fraud and criminal tax cases, including several in this District. [REDACTED] reviewed the Macalvins report and the underlying documents and determined that it presents a complete and accurate summary of the assets held by Ms. Maxwell and her spouse, as well as assets that were, or are currently, held in
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DOJ-OGR-00001993

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