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.
| 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).
|
| 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'.
|
"“Without prejudicing the merits of any of those pending motions,” the judge again denied Ms. Maxwell’s motion for bail"Source
"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
"Ms. Maxwell has documented the Kafkaesque conditions that she is forced to endure."Source
"And to dismiss because the government violated the non-prosecution agreement it reached with Epstein that protected any alleged co-conspirator from prosecution."Source
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