{
  "document_metadata": {
    "page_number": "4",
    "document_number": "20 Cr. 330 (AJN)",
    "date": "December 18, 2020",
    "document_type": "Court Memorandum",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA -v.- GHISLAINE MAXWELL, Defendant. THE GOVERNMENT'S MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S RENEWED MOTION FOR RELEASE 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 1 DOJ-OGR-00001146",
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      "content": "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "UNITED STATES OF AMERICA -v.- GHISLAINE MAXWELL, Defendant.",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "THE GOVERNMENT'S MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S RENEWED MOTION FOR RELEASE",
      "position": "header"
    },
    {
      "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": "body"
    },
    {
      "type": "printed",
      "content": "1",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00001146",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "UNITED STATES DISTRICT COURT",
      "UNITED STATES OF AMERICA",
      "DOJ"
    ],
    "locations": [
      "NEW YORK"
    ],
    "dates": [
      "December 8, 2020",
      "July 14, 2020",
      "December 18, 2020"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00001146"
    ]
  },
  "additional_notes": "The document appears to be a court memorandum in a criminal case. The text is clear and legible, with no visible redactions or damage."
}