DOJ-OGR-00001103.jpg
519 KB
Extraction Summary
4
People
3
Organizations
3
Locations
3
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal memorandum / court filing (preliminary statement for renewed bail motion)
File Size:
519 KB
Summary
This document is the preliminary statement of a legal memorandum filed on December 14, 2020, supporting Ghislaine Maxwell's renewed motion for bail. It outlines new information not present at her initial hearing, including details on family ties in the US, a financial report covering her and her spouse, extradition waivers for the UK and France, and arguments against flight risk. Maxwell asserts her innocence, claims the government's case relies on uncorroborated testimony from 25 years ago, and requests release to prepare her defense.
People (4)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Submitting a renewed motion for release on bail; maintains innocence.
|
| Spouse | Family Member |
Mentioned in the context of a financial report covering assets of Maxwell and her spouse.
|
| Former IRS CID special agent | Expert/Reviewer |
Reviewed the detailed financial report regarding Maxwell's assets.
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| Three accusers | Witnesses/Victims |
Mentioned regarding the government's case lacking corroborative evidence for them.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| IRS CID |
Internal Revenue Service Criminal Investigation Division (referenced regarding the former agent).
|
|
| The Government |
Prosecution; opposing party contending Maxwell evaded detection.
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|
| The Court |
Judicial body overseeing the case.
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Timeline (3 events)
Circa 1995
Circa July 2020
Locations (3)
| Location | Context |
|---|---|
|
Location of Maxwell's significant family ties and where she wishes to remain to fight allegations.
|
|
|
Country for which Maxwell offers an extradition waiver.
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|
|
Country for which Maxwell offers an extradition waiver.
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Relationships (2)
Document mentions financial report concerning 'her financial condition and assets, and those of her spouse'.
Document mentions lack of evidence in support of the three accusers.
Key Quotes (5)
"Ms. Maxwell is proposing an expansive set of bail conditions that is more than adequate to address any concern regarding risk of flight"Source
DOJ-OGR-00001103.jpg
Quote #1
"This information includes... a detailed financial report... concerning her financial condition and assets, and those of her spouse"Source
DOJ-OGR-00001103.jpg
Quote #2
"irrevocable waivers of her right to contest extradition from the United Kingdom and France"Source
DOJ-OGR-00001103.jpg
Quote #3
"Ms. Maxwell vehemently maintains her innocence and is committed to defending herself."Source
DOJ-OGR-00001103.jpg
Quote #4
"allegations against her, which are based on the uncorroborated testimony of a handful of witnesses about events that took place over 25 years ago."Source
DOJ-OGR-00001103.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (2,094 characters)
Case 1:20-cr-00330-AJN Document 102 Filed 12/14/20 Page 1 of 45
PRELIMINARY STATEMENT
Ghislaine Maxwell respectfully submits this Memorandum in Support of her Renewed Motion for Release on Bail.
As set forth more fully below, Ms. Maxwell is proposing an expansive set of bail conditions that is more than adequate to address any concern regarding risk of flight and reasonably assure Ms. Maxwell’s presence in court. Ms. Maxwell also provides compelling additional information in this submission, not available at the time of the initial bail hearing (which was held 12 days after her arrest), that squarely addresses each of the Court’s concerns from the initial hearing and fully supports her release on the proposed bail conditions. This information includes: (1) evidence of Ms. Maxwell’s significant family ties in the United States; (2) a detailed financial report, which has also been reviewed by a former IRS CID special agent, concerning her financial condition and assets, and those of her spouse, for the last five years; (3) irrevocable waivers of her right to contest extradition from the United Kingdom and France and expert opinions stating that it would be highly unlikely that Ms. Maxwell would be able to resist extradition in the implausible event of her fleeing to either country; (4) evidence rebutting the Government’s contention that Ms. Maxwell attempted to evade detection by law enforcement prior to her arrest; and (5) a discussion of the weakness of the government’s case against Ms. Maxwell, including the lack of corroborative, contemporaneous documentary evidence in support of the three accusers.
Ms. Maxwell vehemently maintains her innocence and is committed to defending herself. She wants nothing more than to remain in this country to fight the allegations against her, which are based on the uncorroborated testimony of a handful of witnesses about events that took place over 25 years ago. The Court should grant Ms. Maxwell bail on the restrictive conditions proposed below to ensure her constitutional right to prepare her defense.
DOJ-OGR-00001103
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