DOJ-OGR-00000924.pdf
epstein-pdf-nov2025 PDF 595.7 KB • Feb 4, 2026
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* Case 21-770, Document 20-1, 04/01/2021, 3068530, Page14 of 31
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motions are pending and raise significant legal bars to the prosecution of this matter.
C. The proposed bail package
Ghislaine Maxwell has proposed a significant, compelling, and unprecedented bail package, which gives up or puts at risk everything that she has - her British and French citizenship, all of her and her spouse's assets ($22.5 million), her family's livelihood, and the financial security of her closest friends and family (totaling $5 million). A security company, which will monitor and secure Ms. Maxwell at her home, will also post an unprecedented $1 million bond. Ex.E, I. Ms. Maxwell looks forward to confronting the accusers and clearing her name. She has no intention of fleeing and will be unable to do so if released on bond. This bail package demonstrates these facts in a real way, unlike the government's claims that the evidence against her is strong. Even though a guarantee of appearance is not necessary, the bail package in this case is as close to a guarantee as one can get. There is no legally permissible basis to deny bail.
5 Her spouse would retain $400,000 for living and other expenses.
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* DOJ-OGR-00000924
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