DOJ-OGR-00001187.jpg
449 KB
Extraction Summary
3
People
3
Organizations
4
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal filing (table of contents)
File Size:
449 KB
Summary
This document is the Table of Contents for a legal filing (likely a reply brief in support of a bail motion) filed on December 23, 2020, in the case against Ghislaine Maxwell. The defense argues that the government's case is weak (relying on only three witnesses), that Maxwell has substantial ties to the US (including a spouse whose name is redacted), that she has disclosed all finances for bond, and that the COVID surge at the MDC justifies her release. It also refutes the claim that she is a flight risk or that extradition from France or the UK would be refused.
People (3)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
Subject of the bail motion; arguing for release based on ties to US, finances, and COVID risks.
|
| Spouse | Family Member |
Referenced regarding ties to the US and pledging assets for bond. Name is redacted.
|
| Three Witnesses | Witnesses |
Government's case relies almost exclusively on their testimony.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Government |
Prosecution/Department of Justice
|
|
| MDC |
Metropolitan Detention Center (prison facility)
|
|
| Court |
Judicial body hearing the case
|
Locations (4)
| Location | Context |
|---|---|
|
Location of Maxwell's substantial ties
|
|
|
Mentioned regarding extradition likelihood
|
|
|
Mentioned regarding extradition likelihood
|
|
|
Metropolitan Detention Center, site of COVID surge
|
Relationships (2)
Reference to 'Her Spouse' and pledging 'Her Spouse's Assets'
Legal arguments refuting government assertions
Key Quotes (4)
"The Government Concedes that Its Case Relies Almost Exclusively on the Testimony of Three Witnesses"Source
DOJ-OGR-00001187.jpg
Quote #1
"The Government Asks the Court to Ignore Ms. Maxwell’s Substantial Ties to the United States, Including Her Spouse"Source
DOJ-OGR-00001187.jpg
Quote #2
"The Government’s Assertion that Ms. Maxwell Is 'Adept' at Hiding and Therefore a Flight Risk Is Specious"Source
DOJ-OGR-00001187.jpg
Quote #3
"The Recent COVID Surge at MDC Further Justifies Bail"Source
DOJ-OGR-00001187.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (1,739 characters)
Case 1:20-cr-00330-AJN Document 103-2 Filed 12/23/20 Page 2 of 15
TABLE OF CONTENTS
Page
PRELIMINARY STATEMENT ......................................................................................................... 1
ARGUMENT ..................................................................................................................................... 2
I. The Government Concedes that Its Case Relies Almost Exclusively on the Testimony of Three Witnesses ............................................................................................ 2
II. The Government Has Not Carried Its Burden ........................................................................ 4
A. The Government Asks the Court to Ignore Ms. Maxwell’s Substantial Ties to the United States, Including Her Spouse [REDACTED] ........................................................ 4
B. Ms. Maxwell Has Thoroughly Disclosed Her Finances and Pledged All of Her and Her Spouse’s Assets in Support of Her Bond ...................................................... 5
C. The Government’s Assertion that Ms. Maxwell Is “Adept” at Hiding and Therefore a Flight Risk Is Specious .................................................................................... 7
D. Refusal of Extradition from France or the United Kingdom Is Highly Unlikely ................................................................................................................................ 8
E. The Recent COVID Surge at MDC Further Justifies Bail ................................................ 10
CONCLUSION ................................................................................................................................. 10
i
DOJ-OGR-00001187
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