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Extraction Summary

3
People
2
Organizations
0
Locations
1
Events
1
Relationships
4
Quotes

Document Information

Type: Legal filing / court motion (defense reply regarding bail)
File Size: 578 KB
Summary

This document is page 7 of a legal filing filed on December 23, 2020, arguing for Ghislaine Maxwell's release on bail. The defense contends that Maxwell and her spouse have pledged all their assets and that her spouse has liquidated investments to support the bond, countering the government's argument that she is a flight risk or 'adept at hiding.' The text also disputes government claims regarding the verification of the spouse's financial information.

People (3)

Name Role Context
Ms. Maxwell Defendant
Subject of the bail hearing; defense argues she is not a flight risk.
Her spouse Co-signer/Supporter
Has liquidated investments to help Maxwell; pledged all assets for her bond.
The Government Prosecution
Opposing party arguing Maxwell is a flight risk and 'adept at hiding'.

Organizations (2)

Name Type Context
DOJ
Department of Justice (indicated by footer DOJ-OGR)
The Government
Prosecution team

Timeline (1 events)

2020-12-23
Filing of Document 103-2 in Case 1:20-cr-00330-AJN
Court
Ms. Maxwell Defense Counsel The Government

Relationships (1)

Ms. Maxwell Spousal/Financial Support Her spouse
Spouse liquidated investments to help her; they pledged all assets together; footnote discusses assets brought to the relationship.

Key Quotes (4)

"Ms. Maxwell’s wealth is not a reason to deny her bail."
Source
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Quote #1
"She and her spouse have pledged all of their assets in support of the bond."
Source
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Quote #2
"The government continues to assert the sinister narrative that Ms. Maxwell had 'an expertise at remaining hidden,' and that it would therefore be easy for her to become a fugitive."
Source
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Quote #3
"Her spouse... has had to liquidate his existing investments to help Ms. Maxwell."
Source
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Quote #4

Full Extracted Text

Complete text extracted from the document (2,025 characters)

Case 1:20-cr-00330-AJN Document 103-2 Filed 12/23/20 Page 11 of 15
[REDACTED]
[REDACTED]
[REDACTED] Similarly, the financial report does not include
a future income stream for Ms. Maxwell or her spouse because it presents only historical
and current assets. Even so, Ms. Maxwell has no certain future income stream. Her spouse
[REDACTED]
[REDACTED] and has had to liquidate his existing investments to help Ms. Maxwell. Finally, the
reference to [REDACTED] is gratuitous. Ms. Maxwell had no knowledge of [REDACTED]
[REDACTED]
[REDACTED]
[REDACTED]
But the larger point is this: Ms. Maxwell has proposed a substantial bail package
with multiple co-signers and significant security. She and her spouse have pledged all of
their assets in support of the bond. Ms. Maxwell’s wealth is not a reason to deny her bail. It
is a reason to set appropriately strict conditions that will result in significant financial
consequences to Ms. Maxwell and her friends and family if she leaves the country. The
proposed bail package does exactly that.⁶
C. The Government’s Assertion that Ms. Maxwell Is “Adept” at Hiding and
Therefore a Flight Risk Is Specious
The government continues to assert the sinister narrative that Ms. Maxwell had “an
expertise at remaining hidden,” and that it would therefore be easy for her to become a fugitive.
______________________
⁶ The government’s argument that her spouse’s moral suasion is diminished because Ms. Maxwell brought the
majority of assets to the relationship is nonsensical. (Id. at 24-25). Regardless of whose money it was to begin with,
all of the assets of Ms. Maxwell and her spouse will be forfeited if she flees and her spouse [REDACTED] will be
left with nothing. Furthermore, the government’s assertion that they could not verify the spouse’s financial
information because Ms. Maxwell did not provide his current banking information is false. (Id. at 24 n.9). The
defense provided the spouse’s current banking records and only redacted the name of the bank.
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DOJ-OGR-00020114

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