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798 KB
Extraction Summary
4
People
4
Organizations
0
Locations
3
Events
2
Relationships
4
Quotes
Document Information
Type:
Court filing / legal brief (government memorandum in opposition to bail)
File Size:
798 KB
Summary
This document is page 25 of a Government filing (likely opposing bail) in the case against Ghislaine Maxwell (Case 1:20-cr-00330-AJN), filed on December 28, 2020. It argues that Maxwell is a flight risk who evaded the FBI during her arrest (including wrapping a phone in tin foil) and was deceptive with Pretrial Services regarding her 'vast resources,' which far exceed the $3.8 million she initially disclosed. The text asserts that her wealth and willingness to deceive make detention necessary.
People (4)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the detention hearing; accused of evading FBI, hiding assets, and wrapping a phone in tin foil.
|
| FBI Agents | Law Enforcement |
Agents who approached the defendant during her arrest.
|
| Private Security Guards | Security |
Employed by the defendant; their protocols were allegedly prioritized over FBI directives.
|
| Pretrial Services Officer | Court Official |
Interviewed the defendant regarding her assets.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| FBI | ||
| Pretrial Services | ||
| The Government | ||
| The Court |
Timeline (3 events)
2020 (Date of arrest)
Defendant fled from FBI agents into her home upon their approach.
Defendant's residence
Relationships (2)
Government claims defendant was 'less than candid' about assets during interview.
Defendant followed security protocol over FBI directives.
Key Quotes (4)
"the act of wrapping a cellphone in tin foil has no conceivable relevance to concerns about the press."Source
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Quote #1
"the defendant sought to evade not only the press, but also law enforcement."Source
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Quote #2
"the defendant was less than candid with Pretrial Services regarding the assets in her control."Source
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Quote #3
"the defendant is a person of substantial means with vast resources."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,378 characters)
Case 1:20-cr-00330-AJN Document 100 Filed 12/28/20 Page 25 of 36
(Def. Ex. S ¶ 12). Moreover, the FBI announced themselves as federal agents to the defendant
when they first approached her. Thus, even if the defendant was following her private security’s
protocol when she fled, she did so knowing that she was disobeying the directives of FBI agents,
not members of the media or general public. Those actions raise the very real concern, particularly
in light of the terms of her proposed package, that the defendant would prioritize the directives of
her private security guards over the directives of federal law enforcement. Further, the act of
wrapping a cellphone in tin foil has no conceivable relevance to concerns about the press. The
defense argues that the defendant only took those measures because that particular phone number
had been released to the public, but that just suggests the defendant believed that was the only
number of which law enforcement was aware. In other words, there is still reason to believe, as
the Court previously found, that in the year leading up to her arrest, the defendant sought to evade
not only the press, but also law enforcement. (Tr. 87).
when they first approached her. Thus, even if the defendant was following her private security’s
protocol when she fled, she did so knowing that she was disobeying the directives of FBI agents,
not members of the media or general public. Those actions raise the very real concern, particularly
in light of the terms of her proposed package, that the defendant would prioritize the directives of
her private security guards over the directives of federal law enforcement. Further, the act of
wrapping a cellphone in tin foil has no conceivable relevance to concerns about the press. The
defense argues that the defendant only took those measures because that particular phone number
had been released to the public, but that just suggests the defendant believed that was the only
number of which law enforcement was aware. In other words, there is still reason to believe, as
the Court previously found, that in the year leading up to her arrest, the defendant sought to evade
not only the press, but also law enforcement. (Tr. 87).
Third, the defendant has access to significant wealth. At the initial bail hearing, the
Government expressed doubt that the defendant’s assets were limited to the approximately $3.8
million she reported to Pretrial Services, and noted that it appeared the defendant was less than
candid with Pretrial Services regarding the assets in her control. (Tr. 28-30, 72-73). The finances
outlined in the defense submission confirm the Government’s suspicion that the defendant has
access to far more than $3.8 million, confirm that the defendant was less than candid with Pretrial
Services (and, by extension, the Court) during her interview, and confirm that the defendant is a
person of substantial means with vast resources.⁵ The defendant’s apparent willingness to deceive
Government expressed doubt that the defendant’s assets were limited to the approximately $3.8
million she reported to Pretrial Services, and noted that it appeared the defendant was less than
candid with Pretrial Services regarding the assets in her control. (Tr. 28-30, 72-73). The finances
outlined in the defense submission confirm the Government’s suspicion that the defendant has
access to far more than $3.8 million, confirm that the defendant was less than candid with Pretrial
Services (and, by extension, the Court) during her interview, and confirm that the defendant is a
person of substantial means with vast resources.⁵ The defendant’s apparent willingness to deceive
⁵ As noted above, the Court effectively assumed the defendant had considerably more assets than
those disclosed to Pretrial Services in rejecting defense counsel’s repeated offer to provide a more
fulsome picture of the defendant’s finances and concluding that even assuming the defense could
provide a clearer description of the defendant’s assets, detention was still warranted. (See Tr. 87).
those disclosed to Pretrial Services in rejecting defense counsel’s repeated offer to provide a more
fulsome picture of the defendant’s finances and concluding that even assuming the defense could
provide a clearer description of the defendant’s assets, detention was still warranted. (See Tr. 87).
22
DOJ-OGR-00001167
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