pretrial services
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EFTA00013389.pdf
This document is an internal 'Case-Related Urgent' report dated May 20, 2021, detailing the USAO-SDNY's decision to offer deferred prosecution agreements to correctional officers Tova Noel and Michael Thomas. The officers were previously indicted for falsifying records on the night of Jeffrey Epstein's suicide in August 2019. The agreement requires them to admit guilt, perform community service, and cooperate with the Office of Inspector General's investigation into the institutional failures at the MCC.
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This document is a page from the sentencing transcript of Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on August 22, 2022. The presiding judge rejects Maxwell's complaints about her treatment at the MDC, noting she had ample resources for legal preparation. The judge criticizes Maxwell for a pattern of dishonesty regarding finances and deflection of blame, noting that while she acknowledged the victims' suffering, she failed to accept personal responsibility.
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This document is page 44 of a court transcript from Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell), filed on December 10, 2020. The defense attorney argues to the judge that the defendant, her associates, and the legal team at Haddon Morgan have received death threats and physical threats. The attorney contends these safety concerns are preventing individuals from coming forward to support a bail package and criticizes the government for dismissing the severity of these threats.
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This document is a page from a court transcript dated December 10, 2020, in which the government argues against granting bail to a defendant. The prosecutor highlights the defendant's unexplained wealth, lack of community ties, and willingness to live in hiding as flight risks. The government finds it 'extremely surprising' that the defendant has proposed a bail package with no security, has refused to provide financial details about herself or her spouse, and proposes to live in a transient luxury hotel in Manhattan.
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Page 4 of a court transcript from Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell) dated December 10, 2020. The text records the opening of a remote arraignment and bail hearing, with the Judge (The Court) confirming the presence of counsel Ms. Moe, Court Reporter Kristen Carannante, and Pretrial Services Officer Leah Harmon. The Judge notes the proceeding is being held remotely due to the COVID-19 pandemic under the CARES Act.
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This is a letter dated November 25, 2020, from Ghislaine Maxwell's attorneys at Cohen & Gresser LLP to Judge Alison J. Nathan. The attorneys state their intention to file a renewed motion for bail for Ms. Maxwell and request an 'in camera' conference to discuss filing portions of the motion and supporting materials under seal. They argue for sealing to protect sensitive and private information concerning Ms. Maxwell and the third-party sureties (family and friends) supporting her bail application.
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This legal document is a memorandum from the Government arguing against the defendant's bail proposal. The Government asserts the defendant is a flight risk due to her considerable but undisclosed financial resources, her failure to submit a financial affidavit, and her history of lying under oath, specifically citing two counts of perjury from a 2016 civil suit. The document urges the Court to view the defendant as untrustworthy and deny the bail proposal, which it claims offers no security for her appearance.
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This document is page 24 of a legal filing (Document 18) from July 10, 2020, arguing for Ghislaine Maxwell's release on bail due to COVID-19 risks and the adequacy of the proposed bail package. The defense proposes a $5 million bond co-signed by six individuals (siblings, relatives, friends) and secured by $3.75 million in UK property, along with home detention, GPS monitoring, and travel restrictions to NY districts. A footnote cites *United States v. Boustani* to argue that private security guards are appropriate given Maxwell's circumstances.
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This page from a legal filing (Case 21-770) summarizes Judge Nathan's decision to deny Ghislaine Maxwell bail. The Judge cited Maxwell's 'substantial international ties,' 'extraordinary financial resources,' lack of US ties, and 'demonstrated sophistication' in hiding assets as reasons she poses a significant flight risk. Additionally, the Judge rejected arguments regarding the difficulty of preparing a defense while incarcerated, though mandated that the Government ensure adequate attorney-client communication.
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This legal document excerpt details Judge Nathan's reasoning for denying bail to the defendant, Maxwell. The judge found a significant discrepancy between the $3.5 million in assets Maxwell declared in July 2020 and a later estimate of her and her spouse's net worth at $22.5 million. This, along with an insufficient bail proposal, led the judge to conclude Maxwell demonstrated a lack of candor and remained a significant flight risk.
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This legal document outlines the Court's decision to grant Mr. Robertson release to a halfway house under extremely strict conditions, including home incarceration and GPS monitoring. The Court details numerous restrictions on his movement, communication, and contact with others, believing these measures are sufficient to ensure community safety and prevent flight risk. The document also notes a pretrial conference where Mr. Robertson was warned that any violation would result in immediate reincarceration.
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This document is page 6 of a legal filing (Document 172) dated March 22, 2021, in the case of United States v. Ghislaine Maxwell. The defense argues that Maxwell has been transparent about her assets, including those held jointly with her spouse, and that the government's argument regarding asset control and flight risk is illogical. A footnote strongly defends the integrity of Maxwell's New York legal team against the government's implication that they would use escrow funds to help her flee as a fugitive.
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This document is page 5 of a legal motion filed by Ghislaine Maxwell's defense on March 23, 2021, arguing for bail. It proposes retired Judge William S. Duffey, Jr. as an independent monitor for Maxwell's and her spouse's assets, specifically including proceeds from the sale of her London home, to address the Court's flight risk concerns. The defense argues against the government's claims of 'lack of candor,' citing the harsh conditions (solitary confinement, suicide watch) Maxwell was under when questioned by Pretrial Services.
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This legal document details a court's reasoning for finding a defendant's proposed bail package insufficient to prevent flight risk. Despite proposals for home confinement, GPS monitoring, and custody by a family member, the court concludes that the defendant's vast unrestrained wealth means the financial package does not meaningfully mitigate the possibility of her fleeing.
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This document is page 14 of a court order regarding a bail motion for a Defendant (identified by case number as Ghislaine Maxwell). The text analyzes the Defendant's flight risk in relation to her family ties, specifically discussing a letter of support from her spouse whose identity was initially withheld. The Court notes that while the spouse describes a 'quiet family life,' the Defendant was not living with him at the time of arrest, claimed to be getting divorced, and does not propose living with him if released, which undermines her argument that the marriage prevents flight.
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This document is page 6 of a court order filed on December 30, 2020, in Case 20-cr-00330 (United States v. Ghislaine Maxwell). The text details the Court's rejection of the Defendant's arguments for release on bail, despite her offer to pay for private security guards, her claims of family ties in the US, and her offer to waive extradition rights from the UK and France. The Court concludes that no conditions can reasonably assure her appearance, dismissing arguments regarding COVID-19 prison conditions.
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This is page 6 of a legal defense filing (Reply Memorandum) dated December 28, 2020, in the case of United States v. Ghislaine Maxwell. The defense argues against the government's claim that Maxwell is hiding assets to prepare for flight, stating that her transfers to her spouse were disclosed on tax returns and that her asset estimates from jail were accurate given the circumstances. The document details financial specifics, including a London property used for loans and $4 million controlled by her spouse, with specific details regarding the spouse's assets redacted.
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This document is a defense filing arguing that the government has not met its burden in opposing bail for Ms. Maxwell. It asserts that her spouse and friends have come forward to support her bond, demonstrating strong ties to the U.S., contrary to the government's claims. It also addresses footnotes regarding the government's failure to scrutinize accusers and the defense's ongoing legal challenges to the indictment.
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This court document outlines the Government's argument regarding the defendant's (Ghislaine Maxwell) bail application, focusing on her financial assets and lack of candor. It alleges she transferred the majority of her wealth (over $20 million brought to the marriage versus her husband's $200k) into trusts for her spouse to hide assets, including funds used to buy her New Hampshire hideout. The text highlights discrepancies between her actual wealth and what she disclosed to Pretrial Services.
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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.
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This is page 14 (Bates DOJ-OGR-00001159) of a Government filing in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN), filed December 18, 2020. The prosecution argues against bail, citing the defendant's flight risk, wealth, and ability to frustrate extradition from France or the UK. A critical footnote reveals that in 2018, the defendant and her spouse established a trust account where they both falsely listed their marital status as 'single' on bank forms.
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This document is page 13 of a government filing opposing bail for a female defendant (Ghislaine Maxwell, based on the case number). The prosecution argues she is a flight risk due to her three passports, foreign wealth, and lack of employment or children in the US. It highlights inconsistencies in her statements, noting she previously claimed to be divorcing her husband but is now using the marriage to argue for ties to the US, while simultaneously asking to live with a redacted third party rather than said husband.
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This document is page 4 (stamped page 7 of 36) of a legal filing in United States v. Ghislaine Maxwell (Case 1:20-cr-00330-AJN). It details the Court's reasoning for denying bail and detaining Maxwell, citing her serious flight risk, lack of U.S. ties, French citizenship (non-extradition), and extraordinary financial resources. The Court also noted that Maxwell's financial disclosures to Pretrial Services were likely incomplete.
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This court filing details Ghislaine Maxwell's financial history from 2015 to 2020, citing a 'Macalvins report.' It documents her 2015 net worth ($20.2M), the sale of an NYC apartment for $15M, her 2016 marriage, and the subsequent transfer of assets into a trust controlled by her spouse. Footnotes clarify discrepancies between her self-reported assets during a Pretrial Services interview ($3.8M) and her actual financial standing, attributing the difference to lack of access to records while detained.
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This legal document outlines a series of proposed conditions for the pretrial release of Ms. Maxwell. The conditions include home confinement in New York City with GPS monitoring, supervision by Pretrial Services, surrender of travel documents, and the presence of 24/7 private security guards paid for by Ms. Maxwell. The document argues that these measures, supported by legal precedent from the Second Circuit, are sufficient to ensure she will not flee and will appear in court.
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