{
  "document_metadata": {
    "page_number": "1",
    "document_number": "100-1",
    "date": "12/18/20",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 100-1 Filed 12/18/20 Page 1 of 2 BOIES SCHILLER FLEXNER Sigrid S. McCawley Telephone: (954) 377-4223 Email: smccawley@bsfllp.com December 15, 2020 The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: Annie Farmer submits the following statement in opposition to the Defendant's renewed motion for bail. *** I appreciate the opportunity to again be heard by the Court in this matter and once more request that Ghislaine Maxwell not be released prior to her trial. I write this not only on behalf of myself, but all of the other girls and young women who were victimized by Maxwell. Ghislaine Maxwell sexually abused me as a child and the government has the responsibility to make sure that she stands trial for her crimes. I do not believe that will happen or that any of the women she exploited will see justice if she is released on bail. She has lived a life of privilege, abusing her position of power to live beyond the rules. Fleeing the country in order to escape once more would fit with her long history of anti-social behavior. Drawing on my personal experience with Maxwell and what I have learned of how she has lived since that time, I believe that she is a psychopath. Her abuse of me and many other children and young women is evidence of her disregard for and violation of the rights of others. She has demonstrated a complete failure to accept to responsibility in any way for her actions and demonstrated a complete lack of remorse for her central role in procuring girls for Epstein to abuse. She was both charming and manipulative with me during the grooming process, consistent with what many of the women she abused have described. She has frequently lied to others, including repeatedly lying about me and my family. Maxwell has for decades lived a parasitic lifestyle relying on Epstein and others to fund her lavish existence. Maxwell has repeatedly demonstrated that her primary concern is her own welfare, and that she is willing to harm others if it benefits her. She is quite capable of doing so once more. She will not hesitate to leave the country irrespective of whether others will be on the hook financially for her actions because she lacks empathy, and therefore simply does not care about hurting others. She would in fact be highly motivated to flee in order to reduce the possibility of continued imprisonment, the conditions of which she has continuously complained. Her actions over the last several years and choice to live in isolation for long periods suggest that being comfortable is more BOIES SCHILLER FLEXNER LLP 401 East Las Olas Boulevard, Suite 1200, Fort Lauderdale, FL 33301 | (t) 954 356 0011 | (f) 954 356 0022 | www.bsfflp.com DOJ-OGR-00002198",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 100-1 Filed 12/18/20 Page 1 of 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "BOIES SCHILLER FLEXNER Sigrid S. McCawley Telephone: (954) 377-4223 Email: smccawley@bsfllp.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "December 15, 2020 The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan: Annie Farmer submits the following statement in opposition to the Defendant's renewed motion for bail. *** I appreciate the opportunity to again be heard by the Court in this matter and once more request that Ghislaine Maxwell not be released prior to her trial. I write this not only on behalf of myself, but all of the other girls and young women who were victimized by Maxwell. Ghislaine Maxwell sexually abused me as a child and the government has the responsibility to make sure that she stands trial for her crimes. I do not believe that will happen or that any of the women she exploited will see justice if she is released on bail. She has lived a life of privilege, abusing her position of power to live beyond the rules. Fleeing the country in order to escape once more would fit with her long history of anti-social behavior.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Drawing on my personal experience with Maxwell and what I have learned of how she has lived since that time, I believe that she is a psychopath. Her abuse of me and many other children and young women is evidence of her disregard for and violation of the rights of others. She has demonstrated a complete failure to accept to responsibility in any way for her actions and demonstrated a complete lack of remorse for her central role in procuring girls for Epstein to abuse. She was both charming and manipulative with me during the grooming process, consistent with what many of the women she abused have described. She has frequently lied to others, including repeatedly lying about me and my family. Maxwell has for decades lived a parasitic lifestyle relying on Epstein and others to fund her lavish existence.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Maxwell has repeatedly demonstrated that her primary concern is her own welfare, and that she is willing to harm others if it benefits her. She is quite capable of doing so once more. She will not hesitate to leave the country irrespective of whether others will be on the hook financially for her actions because she lacks empathy, and therefore simply does not care about hurting others. She would in fact be highly motivated to flee in order to reduce the possibility of continued imprisonment, the conditions of which she has continuously complained. Her actions over the last several years and choice to live in isolation for long periods suggest that being comfortable is more",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "BOIES SCHILLER FLEXNER LLP 401 East Las Olas Boulevard, Suite 1200, Fort Lauderdale, FL 33301 | (t) 954 356 0011 | (f) 954 356 0022 | www.bsfflp.com",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002198",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "Annie Farmer",
      "Sigrid S. McCawley",
      "Epstein"
    ],
    "organizations": [
      "BOIES SCHILLER FLEXNER LLP",
      "United States District Court",
      "Southern District of New York"
    ],
    "locations": [
      "New York",
      "Fort Lauderdale",
      "Florida"
    ],
    "dates": [
      "December 15, 2020",
      "12/18/20"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "20 Cr. 330 (AJN)",
      "100-1",
      "DOJ-OGR-00002198"
    ]
  },
  "additional_notes": "The document is a letter from Sigrid S. McCawley to Judge Alison J. Nathan regarding the case United States v. Ghislaine Maxwell. The letter is typed and appears to be a formal legal document. There are no visible stamps or handwritten notes."
}