{
  "document_metadata": {
    "page_number": "2",
    "document_number": "20-cr-330",
    "date": null,
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case1:20-cr-00330-AJN Document611802 Filed 07/23/21 Page 2 of 9\n\nINTRODUCTION\n\nGhislaine Maxwell respectfully submits this Memorandum in Support of her Third Motion for Release on Bail.\n\nAs Ms. Maxwell has stated on numerous occasions and reaffirms here: she has no intention or desire to leave this country. She is an American citizen, has lived in United States for 30 years, has strong family ties and the support of friends and family residing in this country. She wants nothing more than to remain in the United States under whatever conditions the Court deems necessary so that she can effectively prepare for trial and vigorously defend against the 25-year-old charges in the Indictment. Ms. Maxwell has already proposed an expansive and, to our knowledge, unprecedented set of bail conditions that would reasonably assure her appearance. (See Dkt. 97.) In light of the Court's denial of that application (see Dkt. 106), Ms. Maxwell now proposes two additional bail conditions to supplement the extraordinarily restrictive bail package she has already offered.\n\nFirst, Ms. Maxwell will renounce her French and British citizenship to eliminate any opportunity for her to seek refuge in those countries, if the Court so requires.\n\nSecond, Ms. Maxwell will have her and her spouse's assets—excluding funds earmarked for living expenses, for legal fees and other expenses necessary to defend her against the criminal charges in this case and related civil lawsuits and for taxes—placed in a new account that will be monitored by a retired federal District Court judge and former United States Attorney who will function as asset monitor and will have co-signing authority over the account.\n\nThe former condition goes well beyond the extradition waivers that the Court deemed insufficient and should satisfy any concerns the Court may have that Ms. Maxwell may try to seek a safe haven in France or the United Kingdom. (See id. at 11-13). As a non-citizen, Ms. Maxwell will not be able to avail herself of any protections against extradition that may apply to\n\n2\n\nDOJ-OGR-00001234",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case1:20-cr-00330-AJN Document611802 Filed 07/23/21 Page 2 of 9",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "INTRODUCTION",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Ghislaine Maxwell respectfully submits this Memorandum in Support of her Third Motion for Release on Bail.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "As Ms. Maxwell has stated on numerous occasions and reaffirms here: she has no intention or desire to leave this country. She is an American citizen, has lived in United States for 30 years, has strong family ties and the support of friends and family residing in this country. She wants nothing more than to remain in the United States under whatever conditions the Court deems necessary so that she can effectively prepare for trial and vigorously defend against the 25-year-old charges in the Indictment. Ms. Maxwell has already proposed an expansive and, to our knowledge, unprecedented set of bail conditions that would reasonably assure her appearance. (See Dkt. 97.) In light of the Court's denial of that application (see Dkt. 106), Ms. Maxwell now proposes two additional bail conditions to supplement the extraordinarily restrictive bail package she has already offered.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "First, Ms. Maxwell will renounce her French and British citizenship to eliminate any opportunity for her to seek refuge in those countries, if the Court so requires.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Second, Ms. Maxwell will have her and her spouse's assets—excluding funds earmarked for living expenses, for legal fees and other expenses necessary to defend her against the criminal charges in this case and related civil lawsuits and for taxes—placed in a new account that will be monitored by a retired federal District Court judge and former United States Attorney who will function as asset monitor and will have co-signing authority over the account.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The former condition goes well beyond the extradition waivers that the Court deemed insufficient and should satisfy any concerns the Court may have that Ms. Maxwell may try to seek a safe haven in France or the United Kingdom. (See id. at 11-13). As a non-citizen, Ms. Maxwell will not be able to avail herself of any protections against extradition that may apply to",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "2",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001234",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "United States Attorney"
    ],
    "locations": [
      "United States",
      "France",
      "United Kingdom"
    ],
    "dates": [
      "07/23/21"
    ],
    "reference_numbers": [
      "20-cr-330",
      "Dkt. 97",
      "Dkt. 106",
      "DOJ-OGR-00001234"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to Ghislaine Maxwell's bail request. The text is mostly printed, with no handwritten content or stamps visible."
}