{
  "document_metadata": {
    "page_number": "10",
    "document_number": "97",
    "date": "12/14/20",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 97 Filed 12/14/20 Page 10 of 45\n\nNew Information for the Court's Consideration\n\nThe defense has devoted substantial time and effort to compile information that was not available to Ms. Maxwell at the time of the initial bail hearing that squarely addresses each of the factors the Court considered at that hearing. Because of these efforts, Ms. Maxwell can now present the following additional information in support of her renewed bail application:\n\n- Letter from Ms. Maxwell's spouse. This letter demonstrates that Ms. Maxwell has powerful family ties to the United States that she will not abandon. It describes the committed relationship between Ms. Maxwell and her spouse, who is a U.S. citizen, and how they lived a quiet family life together in the United States for over four years immediately prior to her arrest. The letter further explains that Ms. Maxwell was forced to leave her family and drop out of the public eye, not because she was trying to evade law enforcement, but because the intense media frenzy and threats following the arrest and death of Jeffrey Epstein threatened the safety and wellbeing of herself and her family, For these same reasons, Ms. Maxwell's spouse did not come forward as a co-signer at the time of the initial hearing. (Ex. A).\n\n- Letters from numerous other friends and family members. These letters from Ms. Maxwell's other sureties and several family members and friends attest to Ms. Maxwell's strong, forthright character and their confidence that she will not flee. The sureties also describe the significant financial distress they would suffer if Ms. Maxwell were to violate her bail conditions. (Exs. B-N, W-X).\n\n- Financial report. The financial report, prepared by the accounting firm Macalvins Limited, provides an accounting of Ms. Maxwell's financial condition from 2015-2020, and discloses (i) all of her own assets, (ii) all assets held in trust, and (iii) all of the assets held by her spouse over that same time period. The report reflects that the total value of assets in all three categories is approximately $22.5 million, which is the amount of the proposed bond. (Ex. O).\n\n- Report from former IRS agent. a former IRS agent with over 40 years of experience in criminal tax and financial fraud investigations, reviewed the Macalvins report and confirmed that it presents a complete and accurate picture of Ms. Maxwell and her spouse's assets from 2015-2020. (Ex. P).\n\n- Statement from the person in charge of Ms. Maxwell's security. This statement rebuts the government's claim that she attempted to hide from law enforcement at the time of her arrest. (Ex. S).\n\n- Extradition waivers and expert affidavits. To address the Court's concerns about extradition, Ms. Maxwell will present irrevocable written waivers of her right to\n\n4\nDOJ-OGR-00001982",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 97 Filed 12/14/20 Page 10 of 45",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "New Information for the Court's Consideration",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The defense has devoted substantial time and effort to compile information that was not available to Ms. Maxwell at the time of the initial bail hearing that squarely addresses each of the factors the Court considered at that hearing. Because of these efforts, Ms. Maxwell can now present the following additional information in support of her renewed bail application:",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "- Letter from Ms. Maxwell's spouse. This letter demonstrates that Ms. Maxwell has powerful family ties to the United States that she will not abandon. It describes the committed relationship between Ms. Maxwell and her spouse, who is a U.S. citizen, and how they lived a quiet family life together in the United States for over four years immediately prior to her arrest. The letter further explains that Ms. Maxwell was forced to leave her family and drop out of the public eye, not because she was trying to evade law enforcement, but because the intense media frenzy and threats following the arrest and death of Jeffrey Epstein threatened the safety and wellbeing of herself and her family, For these same reasons, Ms. Maxwell's spouse did not come forward as a co-signer at the time of the initial hearing. (Ex. A).",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "- Letters from numerous other friends and family members. These letters from Ms. Maxwell's other sureties and several family members and friends attest to Ms. Maxwell's strong, forthright character and their confidence that she will not flee. The sureties also describe the significant financial distress they would suffer if Ms. Maxwell were to violate her bail conditions. (Exs. B-N, W-X).",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "- Financial report. The financial report, prepared by the accounting firm Macalvins Limited, provides an accounting of Ms. Maxwell's financial condition from 2015-2020, and discloses (i) all of her own assets, (ii) all assets held in trust, and (iii) all of the assets held by her spouse over that same time period. The report reflects that the total value of assets in all three categories is approximately $22.5 million, which is the amount of the proposed bond. (Ex. O).",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "- Report from former IRS agent. a former IRS agent with over 40 years of experience in criminal tax and financial fraud investigations, reviewed the Macalvins report and confirmed that it presents a complete and accurate picture of Ms. Maxwell and her spouse's assets from 2015-2020. (Ex. P).",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "- Statement from the person in charge of Ms. Maxwell's security. This statement rebuts the government's claim that she attempted to hide from law enforcement at the time of her arrest. (Ex. S).",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "- Extradition waivers and expert affidavits. To address the Court's concerns about extradition, Ms. Maxwell will present irrevocable written waivers of her right to",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "4",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001982",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Jeffrey Epstein",
      "Ms. Maxwell's spouse"
    ],
    "organizations": [
      "Macalvins Limited",
      "IRS"
    ],
    "locations": [
      "United States"
    ],
    "dates": [
      "12/14/20",
      "2015-2020"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-AJN",
      "Document 97",
      "Ex. A",
      "Exs. B-N, W-X",
      "Ex. O",
      "Ex. P",
      "Ex. S",
      "DOJ-OGR-00001982"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the bail application of Ms. Maxwell. The text is well-formatted and easy to read. There are no visible redactions or damage to the document."
}