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746 KB
Extraction Summary
3
People
4
Organizations
3
Locations
1
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal filing / court document (bail application)
File Size:
746 KB
Summary
This document is page 4 of a legal filing (bail application) for Ghislaine Maxwell, dated July 10, 2020. The defense argues that the government's concerns about flight risk due to her citizenship and finances are unfounded and notes the alleged crimes are 25 years old. The defense proposes a $5 million bond co-signed by six people, secured by UK property, along with home confinement, GPS monitoring, and strict travel restrictions within New York.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the bail application, seeking release on bond.
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| Unnamed Co-signers | Sureties |
Six financially responsible people with strong ties to Ms. Maxwell proposed to co-sign the bond.
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| The Government | Prosecution |
Opposing party whose arguments regarding flight risk/financial means are being rebutted.
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Organizations (4)
| Name | Type | Context |
|---|---|---|
| Pretrial Services |
Proposed agency to provide strict supervision of Maxwell.
|
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| Southern District of New York |
Location of proposed confinement and travel restriction.
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| Eastern District of New York |
Location of permitted travel.
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| DOJ |
Department of Justice (referenced in footer stamp DOJ-OGR).
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Timeline (1 events)
2020-07-10
Filing of bail application document proposing conditions for release.
Southern District of New York
Defense Counsel
Court
Locations (3)
| Location | Context |
|---|---|
|
Location of real property worth over $3.75 million offered as security.
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Proposed location for home confinement.
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Permitted travel zone.
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Relationships (2)
Document states bond to be co-signed by 'six financially responsible people, all of whom have strong ties to Ms. Maxwell'.
Proposed visitor list limited to these groups.
Key Quotes (4)
"those close to her have suffered the loss of jobs, work opportunities, and reputational damage simply for knowing her."Source
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Quote #1
"alleged conduct that is roughly twenty-five years old"Source
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"(i) a $5 million personal recognizance bond, co-signed by six financially responsible people, all of whom have strong ties to Ms. Maxwell"Source
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Quote #3
"(v) home confinement at a residence in the Southern District of New York with electronic GPS monitoring"Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,231 characters)
Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 8 of 20
Case 1:20-cr-00330-AJN Document 20-2 04/01/2021 3068520 Page 33 of 200
Case 1:20-cr-00330-AJN Document 20-2 04/01/2021 3068520 Page 33 of 200
purpose of protecting herself and those close to her from the crush of media and online attention and its very real harms—those close to her have suffered the loss of jobs, work opportunities, and reputational damage simply for knowing her. The government’s remaining arguments— about Ms. Maxwell’s passports, citizenship, travel and financial means— also fail because they would require that every defendant with multiple citizenship and financial means be denied bail, which is simply not the law. Finally, as discussed below, the government’s position regarding the nature and circumstances of the offense and weight of its evidence, which relates to alleged conduct that is roughly twenty-five years old, is not persuasive and does not alter the bail analysis. (See infra Section II, pages 9 to 21).
Proposed Bail Conditions. In light of the above, we propose the following bail conditions, which are consistent with those that courts in this Circuit have imposed in analogous situations: (i) a $5 million personal recognizance bond, co-signed by six financially responsible people, all of whom have strong ties to Ms. Maxwell, and secured by real property in the United Kingdom worth over $3.75 million; (ii) travel restricted to the Southern and Eastern Districts of New York; (iii) surrender of all travel documents with no new applications; (iv) strict supervision by Pretrial Services; (v) home confinement at a residence in the Southern District of New York with electronic GPS monitoring; (vi) visitors limited to Ms. Maxwell’s immediate family, close friends and counsel; (vii) travel limited to Court appearances and to counsel’s office, except upon application to Pretrial Services and the government; and (viii) such other terms as the Court may deem appropriate under Section 3142.
The Bail Reform Act does not discard the presumption of innocence; Ms. Maxwell is entitled to that presumption here, as she is in all aspects of this case. See 18 U.S.C. § 3142(j) (“Nothing in this section [3142] shall be construed as modifying or limiting the presumption of
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DOJ-OGR-00000964
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