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713 KB

Extraction Summary

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

Document Information

Type: Legal filing (government response to bail application)
File Size: 713 KB
Summary

This document is page 8 of a legal filing (Government's opposition to a renewed bail application) in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330). The text argues that the defense's new application reiterates previously rejected arguments regarding flight risk and ties to the US. It emphasizes that the nature of the charges, involving the sexual abuse of multiple minor victims, supports continued detention.

People (2)

Name Role Context
Ghislaine Maxwell Defendant
Subject of the bail hearing and detention order (implied by case number 1:20-cr-00330 and context)
Jeffrey Epstein Associate of Defendant
Mentioned in relation to the defendant's behavior after his arrest

Organizations (2)

Name Type Context
United States District Court
The court handling the case
Department of Justice (DOJ)
Indicated by Bates stamp DOJ-OGR-00020071

Timeline (3 events)

2020-12-28
Filing of Document 102
Court
Unknown (Prior)
Initial bail hearing
Court
Defendant Defense Court
Unknown (Prior)
Epstein's arrest
Unknown

Locations (1)

Location Context
Mentioned regarding the defendant's ties to the country

Relationships (1)

Ghislaine Maxwell Association Jeffrey Epstein
Document discusses defendant's behavior 'after Epstein's arrest'

Key Quotes (3)

"The Renewed Bail Application largely reiterates the same claims regarding the defendant’s ties to the United States and her behavior after Epstein’s arrest that the Court already found unpersuasive."
Source
DOJ-OGR-00020071.jpg
Quote #1
"defendant "poses a substantial actual risk of flight,""
Source
DOJ-OGR-00020071.jpg
Quote #2
"The charges in the Indictment describe horrendous conduct involving the sexual abuse of multiple minor victims."
Source
DOJ-OGR-00020071.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (2,045 characters)

Case 1:20-cr-00330-AJN Document 102 Filed 12/28/20 Page 11 of 36
reconsideration” by, for example, demonstrating “that the court overlooked information or
incorrectly applied the law,” or that failure to reconsider “would constitute manifest injustice.”
Petrov, 2015 WL 1102286 at *3.
DISCUSSION
Having already raised numerous arguments in its briefing and oral argument at the initial
bail hearing in this case, the defense now asks this Court to reverse itself based on virtually the
same arguments it already rejected. The Renewed Bail Application largely reiterates the same
claims regarding the defendant’s ties to the United States and her behavior after Epstein’s arrest
that the Court already found unpersuasive. To the extent the Renewed Bail Application presents
new information, it consists primarily of financial data that was certainly known to the defendant
at the time of her initial bail application and that the Court already assumed could be made
available (and thus rejected as immaterial) when ordering detention. Ultimately, nothing in the
Renewed Bail Application alters the analysis that led this Court to conclude that the defendant
“poses a substantial actual risk of flight,” and that no combination of conditions could assure her
appearance. (Tr. 86). All three of the relevant Bail Reform Act factors still weigh heavily in favor
of detention, and the defense claims to the contrary do not warrant a revisiting of this Court’s well-
reasoned and thorough prior decision.
A. The Nature and Circumstances of the Offense
The first Bail Reform Act factor indisputably weighs in favor of detention in this case. The
egregious conduct charged in the Indictment gives rise to a statutory presumption of detention, and
the Renewed Bail Motion makes no effort to challenge this Court’s prior conclusion that the nature
and circumstances of the offense support detention. The charges in the Indictment describe
horrendous conduct involving the sexual abuse of multiple minor victims. If convicted, the
8
DOJ-OGR-00020071

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