{
  "document_metadata": {
    "page_number": "8",
    "document_number": "20-cr-330 (AJN)",
    "date": "07/10/20",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 8 of 260\npurpose of protecting herself and those close to her from the crush of media and online attention\nand its very real harms—those close to her have suffered the loss of jobs, work opportunities,\nand reputational damage simply for knowing her. The government's remaining arguments—\nabout Ms. Maxwell's passports, citizenship, travel and financial means—also fail because they\nwould require that every defendant with multiple citizenship and financial means be denied bail,\nwhich is simply not the law. Finally, as discussed below, the government's position regarding\nthe nature and circumstances of the offense and weight of its evidence, which relates to alleged\nconduct that is roughly twenty-five years old, is not persuasive and does not alter the bail\nanalysis. (See infra Section II, pages 9 to 21).\nProposed Bail Conditions. In light of the above, we propose the following bail\nconditions, which are consistent with those that courts in this Circuit have imposed in analogous\nsituations: (i) a $5 million personal recognizance bond, co-signed by six financially responsible\npeople, all of whom have strong ties to Ms. Maxwell, and secured by real property in the United\nKingdom worth over $3.75 million; (ii) travel restricted to the Southern and Eastern Districts of\nNew York; (iii) surrender of all travel documents with no new applications; (iv) strict\nsupervision by Pretrial Services; (v) home confinement at a residence in the Southern District of\nNew York with electronic GPS monitoring; (vi) visitors limited to Ms. Maxwell's immediate\nfamily, close friends and counsel; (vii) travel limited to Court appearances and to counsel's\noffice, except upon application to Pretrial Services and the government; and (viii) such other\nterms as the Court may deem appropriate under Section 3142.\nThe Bail Reform Act does not discard the presumption of innocence; Ms. Maxwell is\nentitled to that presumption here, as she is in all aspects of this case. See 18 U.S.C. § 3142(j)\n(\"Nothing in this section [3142] shall be construed as modifying or limiting the presumption of\n4\nDOJ-OGR-00000964",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 18 Filed 07/10/20 Page 8 of 260",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "purpose of protecting herself and those close to her from the crush of media and online attention\nand its very real harms—those close to her have suffered the loss of jobs, work opportunities,\nand reputational damage simply for knowing her. The government's remaining arguments—\nabout Ms. Maxwell's passports, citizenship, travel and financial means—also fail because they\nwould require that every defendant with multiple citizenship and financial means be denied bail,\nwhich is simply not the law. Finally, as discussed below, the government's position regarding\nthe nature and circumstances of the offense and weight of its evidence, which relates to alleged\nconduct that is roughly twenty-five years old, is not persuasive and does not alter the bail\nanalysis. (See infra Section II, pages 9 to 21).\nProposed Bail Conditions. In light of the above, we propose the following bail\nconditions, which are consistent with those that courts in this Circuit have imposed in analogous\nsituations: (i) a $5 million personal recognizance bond, co-signed by six financially responsible\npeople, all of whom have strong ties to Ms. Maxwell, and secured by real property in the United\nKingdom worth over $3.75 million; (ii) travel restricted to the Southern and Eastern Districts of\nNew York; (iii) surrender of all travel documents with no new applications; (iv) strict\nsupervision by Pretrial Services; (v) home confinement at a residence in the Southern District of\nNew York with electronic GPS monitoring; (vi) visitors limited to Ms. Maxwell's immediate\nfamily, close friends and counsel; (vii) travel limited to Court appearances and to counsel's\noffice, except upon application to Pretrial Services and the government; and (viii) such other\nterms as the Court may deem appropriate under Section 3142.\nThe Bail Reform Act does not discard the presumption of innocence; Ms. Maxwell is\nentitled to that presumption here, as she is in all aspects of this case. See 18 U.S.C. § 3142(j)\n(\"Nothing in this section [3142] shall be construed as modifying or limiting the presumption of",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "4",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00000964",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell"
    ],
    "organizations": [
      "Pretrial Services",
      "Court"
    ],
    "locations": [
      "United Kingdom",
      "New York",
      "Southern District of New York",
      "Eastern Districts of New York"
    ],
    "dates": [
      "07/10/20"
    ],
    "reference_numbers": [
      "20-cr-330 (AJN)",
      "18 U.S.C. § 3142(j)",
      "DOJ-OGR-00000964"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the bail conditions for Ms. Maxwell. The text is printed and there are no visible stamps or handwritten notes. The document is page 8 of 260."
}