DOJ-OGR-00019841.jpg

581 KB

Extraction Summary

5
People
3
Organizations
0
Locations
4
Events
2
Relationships
4
Quotes

Document Information

Type: Legal brief / court filing (appeal document)
File Size: 581 KB
Summary

This document is page 13 of a legal brief (Case 21-58) dated April 1, 2021, appealing a decision to deny Ghislaine Maxwell bail. The text argues that the trial court denied bail based on the government's claims without reviewing actual evidence, while Maxwell endures 'Kafkaesque conditions.' It also outlines 12 pretrial motions filed by the defense, including motions to dismiss based on the statute of limitations, pre-indictment delay, and the violation of Jeffrey Epstein's non-prosecution agreement.

People (5)

Name Role Context
Ghislaine Maxwell Defendant/Appellant
Subject of the bail denial and filer of 12 pretrial motions; described as enduring 'Kafkaesque conditions'.
Jeffrey Epstein Deceased Financier/Co-conspirator
Mentioned regarding the non-prosecution agreement that allegedly protected co-conspirators.
Trial Court Judge Judge
Denied Maxwell's motion for bail based on the government's proffered case strength.
Former federal judge Asset Monitor
Mentioned as controlling/monitoring assets (likely for bail proposal).
Former U.S. Attorney Asset Monitor
Mentioned as controlling/monitoring assets (likely for bail proposal).

Organizations (3)

Name Type Context
The Government
Opposing party in the case; needed 212 pages to respond to Maxwell's motions.
Trial Court
The lower court that denied bail.
Department of Justice (DOJ)
Indicated by the Bates stamp 'DOJ-OGR'.

Timeline (4 events)

2007-2008 (Historical reference)
Non-prosecution agreement reached with Epstein
Florida (Implied)
2021-04-01
Filing date of the document (Appeal Brief)
Court of Appeals (Implied)
Unknown (Prior to 2021-04-01)
Denial of Ms. Maxwell's motion for bail
Trial Court
Unknown (Prior to 2021-04-01)
Filing of 12 pretrial motions by Ms. Maxwell
Trial Court

Relationships (2)

Ghislaine Maxwell Alleged Co-conspirator Jeffrey Epstein
Document mentions an NPA that 'protected any alleged co-conspirator' in context of Maxwell's defense.
Jeffrey Epstein Legal Agreement The Government
Reference to the 'non-prosecution agreement it reached with Epstein'.

Key Quotes (4)

"“Without prejudicing the merits of any of those pending motions,” the judge again denied Ms. Maxwell’s motion for bail"
Source
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Quote #1
"relying in part on the “proffered strength and nature of the Government’s case,” even though, again, no evidence was actually submitted to or reviewed by the trial court."
Source
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Quote #2
"Ms. Maxwell has documented the Kafkaesque conditions that she is forced to endure."
Source
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Quote #3
"And to dismiss because the government violated the non-prosecution agreement it reached with Epstein that protected any alleged co-conspirator from prosecution."
Source
DOJ-OGR-00019841.jpg
Quote #4

Full Extracted Text

Complete text extracted from the document (1,193 characters)

Case 21-58, Document 39-1, 04/01/2021, 3068530, Page13 of 31
assets controlled and monitored by a former federal judge and former
U.S. Attorney. She also cited the 12 pretrial motions she filed.
“Without prejudicing the merits of any of those pending motions,” the
judge again denied Ms. Maxwell’s motion for bail, relying in part on the
“proffered strength and nature of the Government’s case,” even though,
again, no evidence was actually submitted to or reviewed by the trial
court. This appeal follows.
In each of her bail requests and in separate pleadings, Ms.
Maxwell has documented the Kafkaesque conditions that she is forced
to endure. See, e.g., Ex.M.
B. The pretrial motions
Ms. Maxwell filed 12 substantial pretrial motions. Docs. 119-26;
133-48. These include motions to dismiss for violation of the statute of
limitations (Docs. 143-44) and for pre-indictment delay (Docs. 137-38)
because the conduct is so old. And to dismiss because the government
violated the non-prosecution agreement it reached with Epstein that
protected any alleged co-conspirator from prosecution. Docs 141-42. The
government needed 212 pages to respond to these motions. These
11
DOJ-OGR-00019841

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