{
  "document_metadata": {
    "page_number": "4",
    "document_number": "20-cr-330",
    "date": null,
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 611-2 Filed 02/02/21 Page 4 of 9\n\n1. The Proposed Additional Bail Conditions Will Reasonably Assure Ms. Maxwell's Appearance in Court\n\nAs set forth above, Ms. Maxwell now proposes two additional restrictions that eliminate any means or opportunity that she may have to leave the country. The Court should therefore reconsider its earlier ruling and grant bail under the proposed conditions. See United States v. Rowe, No. 02 CR. 756 LM, 2003 WL 21196846, at *1 (S.D.N.Y. May 21, 2003) (\"[A] release order may be reconsidered even where the evidence proffered on reconsideration was known to the movant at the time of the original hearing.\"); see also United States v. Petrov, No. 15-CR-66-LTS, 2015 WL 11022886, at *3 (S.D.N.Y. Mar. 26, 2015) (noting \"Court's inherent authority for reconsideration of the Court's previous bail decision\").\n\nA. Renunciation of Foreign Citizenship\n\nTo demonstrate her commitment to abide by her conditions of release and to provide further assurance to the Court that she will not attempt to leave the country, Ms. Maxwell is willing to formally renounce her foreign citizenships in France and the United Kingdom. Should the Court feel this drastic condition is necessary, the required documents will be submitted to the appropriate authorities. Moreover, as a standard condition of bail, all of Ms. Maxwell's passports will be surrendered to the government and no further application will be made.\n\nIf the Court deems it a necessary condition of release, Ms. Maxwell will formally commence the procedure to renounce her foreign citizenship. The requisite paperwork is in the process of being completed. Renunciation of UK citizenship can be accomplished immediately upon granting of bail. The process of renouncing her French citizenship, while not immediate, may be expedited.\n\nCitizenship is a precious and priceless asset. Ms. Maxwell's decision to give up citizenship from the county of her birth and the country of her upbringing demonstrates her 4\n\nDOJ-OGR-00001236",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 611-2 Filed 02/02/21 Page 4 of 9",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1. The Proposed Additional Bail Conditions Will Reasonably Assure Ms. Maxwell's Appearance in Court",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "As set forth above, Ms. Maxwell now proposes two additional restrictions that eliminate any means or opportunity that she may have to leave the country. The Court should therefore reconsider its earlier ruling and grant bail under the proposed conditions. See United States v. Rowe, No. 02 CR. 756 LM, 2003 WL 21196846, at *1 (S.D.N.Y. May 21, 2003) (\"[A] release order may be reconsidered even where the evidence proffered on reconsideration was known to the movant at the time of the original hearing.\"); see also United States v. Petrov, No. 15-CR-66-LTS, 2015 WL 11022886, at *3 (S.D.N.Y. Mar. 26, 2015) (noting \"Court's inherent authority for reconsideration of the Court's previous bail decision\").",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "A. Renunciation of Foreign Citizenship",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "To demonstrate her commitment to abide by her conditions of release and to provide further assurance to the Court that she will not attempt to leave the country, Ms. Maxwell is willing to formally renounce her foreign citizenships in France and the United Kingdom. Should the Court feel this drastic condition is necessary, the required documents will be submitted to the appropriate authorities. Moreover, as a standard condition of bail, all of Ms. Maxwell's passports will be surrendered to the government and no further application will be made.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "If the Court deems it a necessary condition of release, Ms. Maxwell will formally commence the procedure to renounce her foreign citizenship. The requisite paperwork is in the process of being completed. Renunciation of UK citizenship can be accomplished immediately upon granting of bail. The process of renouncing her French citizenship, while not immediate, may be expedited.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Citizenship is a precious and priceless asset. Ms. Maxwell's decision to give up citizenship from the county of her birth and the country of her upbringing demonstrates her 4",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001236",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell"
    ],
    "organizations": [
      "Court",
      "United States"
    ],
    "locations": [
      "France",
      "United Kingdom",
      "UK"
    ],
    "dates": [
      "02/02/21",
      "May 21, 2003",
      "Mar. 26, 2015"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "02 CR. 756 LM",
      "15-CR-66-LTS",
      "DOJ-OGR-00001236"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the bail conditions of Ms. Maxwell. The text is printed and there are no visible stamps or handwritten notes. The document is page 4 of 9."
}