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688 KB
Extraction Summary
2
People
3
Organizations
2
Locations
2
Events
1
Relationships
4
Quotes
Document Information
Type:
Legal filing / court motion (defense memorandum)
File Size:
688 KB
Summary
This page from a defense filing (dated Dec 23, 2020) argues that Ghislaine Maxwell accurately disclosed her assets to Pretrial Services despite being in jail without records. The defense rebuts the government's claim that she is hiding wealth or has 'unrestrained funds' to flee, citing a negative pledge on her London property and the illiquidity of $4 million controlled by her spouse.
People (2)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Arguing against government assertions regarding her asset disclosure and flight risk.
|
| Spouse | Family Member |
Mentioned in relation to asset transfers, trusts, and controlling $4 million in assets.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Pretrial Services |
Agency that interviewed Maxwell in jail to estimate assets.
|
|
| The Government |
Prosecution/DOJ arguing Maxwell is hiding assets and is a flight risk.
|
|
| DOJ |
Department of Justice (referenced in Bates stamp DOJ-OGR-00002216).
|
Timeline (2 events)
2020-12-23
Filing of Document 103 in Case 1:20-cr-00330-AJN
Federal Court
Defense Counsel
Court
Relationships (1)
Reference to 'her spouse', joint tax returns, and transferring assets to him.
Key Quotes (4)
"The government asserts that Ms. Maxwell has demonstrated 'sophistication in hiding her assets'"Source
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Quote #1
"characterizes her transfers to a trust as 'funneling' assets to her spouse to 'hide her true wealth.'"Source
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Quote #2
"There is nothing unusual, let alone nefarious or even particularly sophisticated about transferring assets into a trust or a spouse."Source
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Quote #3
"Ms. Maxwell has procured significant loans on the basis of a negative pledge over her London property."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,198 characters)
Case 1:20-cr-00330-AJN Document 103 Filed 12/23/20 Page 10 of 15
The report shows nothing of the sort. Ms. Maxwell, who was sitting in a jail cell at the time,
was asked by Pretrial Services to estimate her assets. Accordingly, she gave her best
estimate of the assets she held in her own name, which the government concedes she did
with remarkable accuracy considering that she had not reviewed her financial statements.⁵
was asked by Pretrial Services to estimate her assets. Accordingly, she gave her best
estimate of the assets she held in her own name, which the government concedes she did
with remarkable accuracy considering that she had not reviewed her financial statements.⁵
The government’s arguments further confirm that it has lost all objectivity and will
view at any fact involving Ms. Maxwell in the worst possible light. For example, the
government asserts that Ms. Maxwell has demonstrated “sophistication in hiding her assets”
and characterizes her transfers to a trust as “funneling” assets to her spouse to “hide her true
wealth.” (Id. at 24). There is nothing unusual, let alone nefarious or even particularly
sophisticated about transferring assets into a trust or a spouse. Indeed, Ms. Maxwell fully
disclosed these transactions on her joint tax returns. More importantly, all of the assets
disclosed in the financial report, whether they are owned by Ms. Maxwell or her spouse, are
included in the bond amount and are subject to forfeiture if she flees.
view at any fact involving Ms. Maxwell in the worst possible light. For example, the
government asserts that Ms. Maxwell has demonstrated “sophistication in hiding her assets”
and characterizes her transfers to a trust as “funneling” assets to her spouse to “hide her true
wealth.” (Id. at 24). There is nothing unusual, let alone nefarious or even particularly
sophisticated about transferring assets into a trust or a spouse. Indeed, Ms. Maxwell fully
disclosed these transactions on her joint tax returns. More importantly, all of the assets
disclosed in the financial report, whether they are owned by Ms. Maxwell or her spouse, are
included in the bond amount and are subject to forfeiture if she flees.
The government further argues that the financial condition report shows that Ms.
Maxwell has access to millions of dollars of “unrestrained funds” that she could use to flee
the country and reimburse any of her sureties for the loss of their security. (Id. at 23). That
characterization is simply untrue. First, as disclosed in the financial report, Ms. Maxwell
has procured significant loans on the basis of a negative pledge over her London property.
Second, the $4 million controlled by her spouse [REDACTED]
could only be liquidated with considerable difficulty.
Maxwell has access to millions of dollars of “unrestrained funds” that she could use to flee
the country and reimburse any of her sureties for the loss of their security. (Id. at 23). That
characterization is simply untrue. First, as disclosed in the financial report, Ms. Maxwell
has procured significant loans on the basis of a negative pledge over her London property.
Second, the $4 million controlled by her spouse [REDACTED]
could only be liquidated with considerable difficulty.
The government also faults Ms. Maxwell for not including a valuation of future
contingent assets and income that may never materialize. (Id. at 23-24). For example, [REDACTED]
contingent assets and income that may never materialize. (Id. at 23-24). For example, [REDACTED]
⁵ Moreover, for the reasons discussed in our initial memorandum, Ms. Maxwell was reluctant to discuss anything
about her spouse and clearly expressed her reluctance to Pretrial Services early on in the interview.
about her spouse and clearly expressed her reluctance to Pretrial Services early on in the interview.
6
DOJ-OGR-00002216
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