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Extraction Summary
3
People
4
Organizations
2
Locations
2
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal motion (bail application/memorandum)
File Size:
521 KB
Summary
This document is page 35 of a legal filing (Document 102) dated December 14, 2020, arguing for Ghislaine Maxwell's release on bail. The defense argues she is not a flight risk and that her current detention at the MDC constitutes 'de facto solitary confinement' under conditions more severe than USP Florence ADMAX, hindering her ability to prepare her defense. It claims prison wardens have noted the unprecedented nature of her restrictive regime.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the bail application, currently detained.
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| Jeffrey Epstein | Deceased/Co-conspirator |
Mentioned as a reference point for time ('since Epstein's arrest').
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| Wardens and Interim Wardens | Prison Officials |
Unnamed officials who allegedly remarked on the severity of Maxwell's confinement regime.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| MDC |
Facility where Maxwell is currently detained.
|
|
| USP Florence ADMAX |
Supermax prison used as a comparison for the severity of Maxwell's conditions.
|
|
| The Government |
Prosecution/Opposing party in the legal case.
|
|
| 8th Cir. |
Court cited in legal precedent (United States v. Orta).
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Timeline (2 events)
Locations (2)
| Location | Context |
|---|---|
Relationships (2)
Reference to 'Epstein's arrest' as a pivotal moment for Maxwell's actions regarding her family.
She is fighting to protect them and flight would 'destroy the family'.
Key Quotes (5)
"Ms. Maxwell has no intention of fleeing."Source
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Quote #1
"If she did, then under the proposed bail conditions she would lose everything and destroy the family she has been fighting so hard to protect since Epstein’s arrest."Source
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Quote #2
"Ms. Maxwell has spent the entirety of her detention now over five months in de facto solitary confinement"Source
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Quote #3
"conditions that rival those used at USP Florence ADMAX"Source
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Quote #4
"multiple wardens and interim wardens have remarked that in their collective years of experience they have never seen anything like her current regime."Source
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Quote #5
Full Extracted Text
Complete text extracted from the document (2,157 characters)
Case 1:20-cr-00330-AJN Document 102 Filed 12/14/20 Page 35 of 45
11-12). Ms. Maxwell is not obligated to rebut every theoretical possibility that the government
might raise that may contribute to a potential flight risk in order to be granted bail. That is not
the standard. Cf. United States v. Orta, 760 F.2d 887, 888 n.4, 892-93 (8th Cir. 1985) (“The
legal standard required by the [Bail Reform] Act is one of reasonable assurances, not absolute
guarantees.”). Ms. Maxwell has no intention of fleeing. If she did, then under the proposed bail
conditions she would lose everything and destroy the family she has been fighting so hard to
protect since Epstein’s arrest. Ms. Maxwell will not do that, and should be granted bail.
might raise that may contribute to a potential flight risk in order to be granted bail. That is not
the standard. Cf. United States v. Orta, 760 F.2d 887, 888 n.4, 892-93 (8th Cir. 1985) (“The
legal standard required by the [Bail Reform] Act is one of reasonable assurances, not absolute
guarantees.”). Ms. Maxwell has no intention of fleeing. If she did, then under the proposed bail
conditions she would lose everything and destroy the family she has been fighting so hard to
protect since Epstein’s arrest. Ms. Maxwell will not do that, and should be granted bail.
G. The Alternative to Bail Is Confinement Under Oppressive Conditions
that Impact Ms. Maxwell’s Health and Ability to Prepare Her Defense
that Impact Ms. Maxwell’s Health and Ability to Prepare Her Defense
Granting bail to Ms. Maxwell is all the more appropriate and necessary because the past
few months have shown that Ms. Maxwell cannot adequately participate in her defense and
prepare for trial from the inside the MDC. The alternative to release is her continued
confinement under extraordinarily onerous conditions that are not only unjust and punitive, but
also meaningfully impair Ms. Maxwell’s ability to review the voluminous discovery produced by
the government and to communicate effectively with counsel to prepare her defense.
few months have shown that Ms. Maxwell cannot adequately participate in her defense and
prepare for trial from the inside the MDC. The alternative to release is her continued
confinement under extraordinarily onerous conditions that are not only unjust and punitive, but
also meaningfully impair Ms. Maxwell’s ability to review the voluminous discovery produced by
the government and to communicate effectively with counsel to prepare her defense.
Ms. Maxwell has spent the entirety of her detention now over five months in de facto
solitary confinement, under conditions that rival those used at USP Florence ADMAX to
supervise the most dangerous inmates in the federal system and are tantamount to imprisonment
as a defendant convicted of capital murder and incarcerated on death row. In fact, multiple
wardens and interim wardens have remarked that in their collective years of experience they
have never seen anything like her current regime. The restrictive regulations to which Ms.
Maxwell is subjected are not reasonably related to a legitimate goal to ensure the security of Ms.
Maxwell or the MDC. Instead, it seems clear that the overly restrictive conditions are an
solitary confinement, under conditions that rival those used at USP Florence ADMAX to
supervise the most dangerous inmates in the federal system and are tantamount to imprisonment
as a defendant convicted of capital murder and incarcerated on death row. In fact, multiple
wardens and interim wardens have remarked that in their collective years of experience they
have never seen anything like her current regime. The restrictive regulations to which Ms.
Maxwell is subjected are not reasonably related to a legitimate goal to ensure the security of Ms.
Maxwell or the MDC. Instead, it seems clear that the overly restrictive conditions are an
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DOJ-OGR-00001137
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