{
  "document_metadata": {
    "page_number": "4",
    "document_number": "100",
    "date": "12/18/20",
    "document_type": "Court Memorandum",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 100 Filed 12/18/20 Page 4 of 36\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n\nUNITED STATES OF AMERICA\n-v.-\nGHISLAINE MAXWELL,\nDefendant.\n\nTHE GOVERNMENT'S MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S RENEWED MOTION FOR RELEASE\n\nThe Government respectfully submits this memorandum in opposition to the defendant's renewed motion for release on bail, dated December 8, 2020 (the \"Renewed Bail Motion\"). Five months ago, after thorough briefing and a nearly two-hour hearing, this Court concluded that the defendant posed a serious flight risk and that no condition or combination of conditions could ensure her appearance in court. The defense now asks this Court to reverse that finding by essentially repackaging its prior arguments and presenting a more specific bail package. However, at the July 14, 2020 bail hearing in this case, this Court rejected the defendant's request to keep the record open to allow the defendant to do precisely what she has done here—namely, present more detailed information about her finances and a more concrete package—determining that further information about her financial picture would be irrelevant because no combination of conditions could ensure this defendant's appearance. The Court's conclusion was plainly correct, and the Renewed Bail Motion does nothing to undermine it. The offense conduct outlined in the Indictment remains incredibly serious, the evidence against the defendant remains strong, and the defendant continues to have extensive financial resources and foreign ties, as well as the\n\n1\nDOJ-OGR-00002165",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 100 Filed 12/18/20 Page 4 of 36",
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    {
      "type": "printed",
      "content": "UNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "UNITED STATES OF AMERICA\n-v.-\nGHISLAINE MAXWELL,\nDefendant.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "THE GOVERNMENT'S MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S RENEWED MOTION FOR RELEASE",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Government respectfully submits this memorandum in opposition to the defendant's renewed motion for release on bail, dated December 8, 2020 (the \"Renewed Bail Motion\"). Five months ago, after thorough briefing and a nearly two-hour hearing, this Court concluded that the defendant posed a serious flight risk and that no condition or combination of conditions could ensure her appearance in court. The defense now asks this Court to reverse that finding by essentially repackaging its prior arguments and presenting a more specific bail package. However, at the July 14, 2020 bail hearing in this case, this Court rejected the defendant's request to keep the record open to allow the defendant to do precisely what she has done here—namely, present more detailed information about her finances and a more concrete package—determining that further information about her financial picture would be irrelevant because no combination of conditions could ensure this defendant's appearance. The Court's conclusion was plainly correct, and the Renewed Bail Motion does nothing to undermine it. The offense conduct outlined in the Indictment remains incredibly serious, the evidence against the defendant remains strong, and the defendant continues to have extensive financial resources and foreign ties, as well as the",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002165",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "UNITED STATES DISTRICT COURT",
      "UNITED STATES OF AMERICA"
    ],
    "locations": [
      "NEW YORK"
    ],
    "dates": [
      "December 8, 2020",
      "July 14, 2020",
      "12/18/20"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 100",
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00002165"
    ]
  },
  "additional_notes": "The document appears to be a court memorandum in a criminal case, with no visible redactions or damage."
}