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825 KB
Extraction Summary
3
People
3
Organizations
3
Locations
2
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal filing / court motion (bail application argument)
File Size:
825 KB
Summary
This document is a page from a legal filing (dated March 23, 2021) arguing for Ghislaine Maxwell's release on bail, citing the Reform Act and proposing a strict bail package including an eight-figure bond, renunciation of foreign citizenship, and asset monitoring by a retired judge. The text argues that her continued detention impairs her ability to prepare for trial and subjects her to a 'trial by public opinion.' A lengthy footnote details poor detention conditions at the MDC, including delayed legal mail, technical issues with electronic discovery, and ventilation issues in visiting rooms characterized by an expert as a 'death trap.'
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the bail motion; described as a 59-year-old woman with no criminal history, detained at MDC.
|
| Unnamed Retired Federal District Court Judge | Proposed Monitor |
Proposed to monitor Maxwell's assets as part of the bail package.
|
| Unnamed HVAC Expert | Expert Witness |
Retained by Federal Defenders of New York; characterized the MDC visiting rooms as a 'death trap'.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| MDC | ||
| Federal Defenders of New York | ||
| DOJ |
Timeline (2 events)
2021-03-23
Filing of Document 120 in Case 1:20-cr-00330-AJN
Federal Court (SDNY implied)
Defense Counsel
Locations (3)
| Location | Context |
|---|---|
|
Described as Maxwell's home for the past 30 years.
|
|
|
Specific location within the MDC where Ms. Maxwell is detained.
|
|
|
Implied location of the Federal Defenders and the court.
|
Relationships (2)
Federal Defenders retained an HVAC expert to review the facility where Maxwell is detained.
Proposed bail package includes asset monitoring by the retired judge.
Key Quotes (5)
"Ms. Maxwell must be released unless there are 'no conditions' that would reasonably assure her presence."Source
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Quote #1
"To find there are absolutely no conditions to satisfy flight risk of a 59-year-old woman with no criminal history... is incredulous."Source
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Quote #2
"The government gains a strategic advantage each day Ms. Maxwell remains in custody – her case is tried daily in the court of public opinion..."Source
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Quote #3
"The visiting rooms in the East Building... have been characterized as a 'death trap.'"Source
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Quote #4
"Ms. Maxwell continues to experience difficulty reviewing electronic discovery..."Source
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Quote #5
Full Extracted Text
Complete text extracted from the document (2,699 characters)
Case 1:20-cr-00330-AJN Document 120 Filed 03/23/21 Page 10 of 18
Reform Act, Ms. Maxwell must be released unless there are "no conditions" that would
reasonably assure her presence. Here, the proposed bail package - uniquely strengthened
by Ms. Maxwell's agreement to renunciate her foreign citizenship and have assets
monitored by a retired federal district court judge - satisfies the actual governing standard.
reasonably assure her presence. Here, the proposed bail package - uniquely strengthened
by Ms. Maxwell's agreement to renunciate her foreign citizenship and have assets
monitored by a retired federal district court judge - satisfies the actual governing standard.
To find there are absolutely no conditions to satisfy flight risk of a 59-year-old
woman with no criminal history, who poses no danger to the community, who has made
America her home for the past 30 years, and who has established strong roots and forged
important connections with family and friends who reside here, is incredulous. The
concerns regarding foreign citizenship and restraint of assets have been addressed. To say
that renunciation of foreign citizenship and strict monitoring of assets by a retired federal
district court judge does not suffice when combined with an eight-figure bond secured by
real property and cash and the strictest terms of home confinement and electronic
monitoring strains credulity. The government gains a strategic advantage each day Ms.
Maxwell remains in custody – her case is tried daily in the court of public opinion based
on allegations that are inadmissible in a court of law; the likelihood of seating jurors who
are not implicitly biased against her is being severely jeopardized; her physical strength
and concentration are becoming increasingly impaired by the conditions of her
confinement; and she is being denied a full and fair opportunity to prepare her case for
trial. 8
woman with no criminal history, who poses no danger to the community, who has made
America her home for the past 30 years, and who has established strong roots and forged
important connections with family and friends who reside here, is incredulous. The
concerns regarding foreign citizenship and restraint of assets have been addressed. To say
that renunciation of foreign citizenship and strict monitoring of assets by a retired federal
district court judge does not suffice when combined with an eight-figure bond secured by
real property and cash and the strictest terms of home confinement and electronic
monitoring strains credulity. The government gains a strategic advantage each day Ms.
Maxwell remains in custody – her case is tried daily in the court of public opinion based
on allegations that are inadmissible in a court of law; the likelihood of seating jurors who
are not implicitly biased against her is being severely jeopardized; her physical strength
and concentration are becoming increasingly impaired by the conditions of her
confinement; and she is being denied a full and fair opportunity to prepare her case for
trial. 8
____________________
8 Ms. Maxwell continues to experience difficulty reviewing electronic discovery, including discs that can only be
reviewed on the MDC computer but are not readable on that computer, and thousands of pages still not readable on
either the MDC computer or the laptop. Her receipt of legal mail – including pretrial motions, responses and replies
– are constantly delayed even after tracking information confirms delivery to the MDC. The visiting rooms in the
East Building, where Ms. Maxwell is detained, have been reviewed by an HVAC expert retained by the Federal
Defenders of New York and have been characterized as a "death trap." The MDC claims it is in the process of
installing HEPA filters, a request long overdue in light of concerns regarding ventilation in legal visiting rooms
raised early in the pandemic. The alternative – to meet in the open-area where social visiting had been conducted-
affords no privacy for confidential attorney-client communication, especially under constant oversight by Ms.
8 Ms. Maxwell continues to experience difficulty reviewing electronic discovery, including discs that can only be
reviewed on the MDC computer but are not readable on that computer, and thousands of pages still not readable on
either the MDC computer or the laptop. Her receipt of legal mail – including pretrial motions, responses and replies
– are constantly delayed even after tracking information confirms delivery to the MDC. The visiting rooms in the
East Building, where Ms. Maxwell is detained, have been reviewed by an HVAC expert retained by the Federal
Defenders of New York and have been characterized as a "death trap." The MDC claims it is in the process of
installing HEPA filters, a request long overdue in light of concerns regarding ventilation in legal visiting rooms
raised early in the pandemic. The alternative – to meet in the open-area where social visiting had been conducted-
affords no privacy for confidential attorney-client communication, especially under constant oversight by Ms.
9
DOJ-OGR-00001264
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