MEMY-1805 marker2 ds9 (salt 4090): 16000/75016

marker2/ds9/EFTA00083270/EFTA00083270.md

@@ -0,0 +1,946 @@
+Edited on June 21, 2018
+
+This was sent to all investigative offices in Massachusetts many times about a cocaine trafficker and child predator the police do dose business with. I am editing this document on July 3, 2020 to remove some information as I would like to solely confine it to Mr. O'Connell. I had questioned why LE and this group of police rarely investigates or arrests the wealthy white drug dealers, including O'Connell and his male family members, and why these troopers and politicians do business with him.
+
+A man with a sordid past who seems to have mimicked the actions of predator Jeffrey Epstein, actions such as having females bring his child victims to him for sex.
+
+DEVAL L PATRICK
+
+ooventroR
+
+MARY ELIZABETH HEFFERNAN SECRETARY
+
+COLONEL MARIAN J. McGOVERN SUOERWIENDINT
+
+> TO: Captain FROM: Trooper #2791 SUBJECT: Summary of Facts CASE NUMBER: 2011-112-0112/ Relative to aSexual Assault - Quincy
+
+Canton, MA 02021
+
+I. The following is a preliminary report and does not contain all information relative to this criminal investigation.
+
+2. After making an initial disclosure of asexual relationship with an older man to a friend, <sup>a</sup> female juvenile known to the commonwealth went to the Norfolk Advocates for Children in Foxboro on Wednesday, March 30, 2011 and had aSAIN (Sexual Assault Intervention Network) interview. During the interview, this female juvenile provided astatement alleging that she had been having asexual relationship with a72 year old white male. During her interview, the juvenile stated that she was introduced to the man in the spring or summer of 2009 when she was <sup>14</sup>years old through awoman friend of hers by the name of Phyllis Capuano, a.k.a. "Kookie". Prior to the juvenile's arrival at the man's Quincy, MA residence, it was explained to the juvenile by Capuano that the male would provide payment for sex. The juvenile described in detail how she and Capuano in front of the man to include
+
+You see, Bill O'Connell was arrested and convicted of cocaine trafficking, but this arrest came only because a fourteen year old girl accused him of raping her for one year. They had to arrest him and he had many grams of cocaine on him when arrested.
+
+Can anyone tell me when one of these top wealthy dealers was arrested in MA ? They aren't and in some cases they are even protected ! It also appears to me that one cop tied to him hacked this document to delete information on it. I also found some of the below Ebay accounts appear to have been canceled and reissued by a random person. This hides who the original owner of that account was and hides the cops ties to O'Connell.
+
+Ebay accounts are used to pass money via Paypal and these cops have transactions with O'Connell. Below is one woman who pimped the child out for money and gifts.
+
+Everett woman as his co-conspirator in one of the incidents.
+
+![](_page_2_Picture_2.jpeg)
+
+Phyllis Capuano. 21, has been indicted on charges that stem from several alleged statutory rapes of a now 15-yearold girl over a two-year period — SitterCity corn
+
+A grand jury returned a total of 17 indictments Monday against William S. O'Connell, 71, and Phyllis Capuano, 21, on charges that stem from several alleged statutory rapes of a now 1S-year-old girl over a two-year period.
+
+O'Connell faces four counts of statutory rape, each of which stem from separate incidents. Capuano's charges stem from one of those incidents, which are alleged to have taken place between June and September of 2009.
+
+O'Connell was indicted on 12 charges; Capuano on five.
+
+Both are charged with committing statutory rape in the 2009 incident, as well as conspiring with and aiding the other
+
+Guess what happened to this young victim of this wealthy and influential man who is closely tied to politicians and these MA troopers?
+
+She just happened to be killed in a "fiery crash" one week before his trial was to begin sp he got off many child rape charges, and she is one reason I created this document.
+
+www.heraldnews.com artrcle NEWS •
+
+Alleged victim in O'Connell case 'haunted' to the end - News - The -.-
+
+Rebecca Resendez, the alleged victim in the statutory rape case against Quincy developer
+
+William O'Connell, was killed in a fiery car crash early Tuesday . .
+
+His name is Wm O'Connell and he is a part of this donor 'Enterprise'. He's another who wants me silenced. Me and many others feel this influential pedophile needs to be investigated, including the child's sudden death.
+
+Has O'Connell ever communicated with Jeff Epstein? I cannot confirm whether he did or not, but you will find some eerie similarities within these documents. I know he drove his yacht to the Carribean, but I don't know if that was to visit Epstein's island, and I know this group has ties to the wealthy in Manhattan who were arrested for paying bribes to NYPD. But today I found they have accounts using the name of Ghislaine and appear they may be tied to the Granite Reality-Realty Group who claim to own her home. Below you can see a few tied to Bill O'Connell, but there are many more than that, and the BNEG nightclub owners have over one hundred realty companies they silently control and own. (Many tied to Seaport where Granite is located)
+
+In September, William was arraigned in Norfolk Superior Court on charges including four counts of statutory rape, one count of cocaine trafficking, and two counts of committing an unnatural and lascivious act with a child under i6. Statutory rape convictions carry a minimum sentence of to years per charge. (William pleaded not guilty to all charges.) He retains a prominent role in three other development corporations — O'Connell Denver Properties Inc., Seaport Aviation Inc., and Seaview Real Estate Inc. — and, pending trial, is allowed to travel to Florida, Colorado, and New York for business, though he must submit to regular drug screenings and cannot
+
+As soon as I heard the name Granite Reality and McClellen & Fish, I began checking into them. I did this because for many years I've sent in their extensive billion dollar hidden real estate, the many real estate companies and investment companies owned by these police and nightclub owners, and their online mortgage and loan companies. (They have many straw buyers but they silently own and control them).
+
+Aside from that, I've found almost one billion in nonprofits they own using fictitious names and tied to these law firms, so I may have found a connection. If they are connected to Epstein and Ghislaine, it would be this underground group who placed her in that home. (see below)
+
+I found more information on the above than I thought I would, and my new document titled Epstein, Ghislaine, and O'Connell ties is below. Harboring a fugitive? This document was added on 7-5-2o2o.
+
+Ghislaine Maxwell and her MA-NH ties...
+
+https://docs.google.com/document/d/1DILdQv9FMJFM -qe-SyJsvr4Yp8006sDgliOZ3 zDwhc/edit?usp=sharing
+
+If you send this document back to Massachusetts nothing will happen to him. I've tried and I received nothing but more abuse from the corrupt police who support him. They all protect one another and you will see why if you view my other documents.
+
+This group chose to surveil and chase me around state to state and year after year all in a bid to silence this information, yet hidden under the guise of a legitimate investigation. Over ten years straight and still no charges. Why? Because they are really doing this to watch me with hopes of protecting the wealthy I've been reporting, and I've sent ample proof showing this over the last eight years.
+
+A crime is investigated and not a person. You don't investigate a person to wait for them to commit a crime, so what crime did I commit twenty years ago when this began and just after I divorced a trooper who has always stalked me? There can't be a different interpretation of law for the wealthy and the common man. From day one, MA law enforcement has been trying to bail out the corrupted troopers and wealthy committing crimes, as well as the police's heinous and blatant corruption, but chasing me around with hopes of silencing me. Aside from that, how come they're not investigating the troopers stolen overtime ten years back? Why only one year ago when most people know all of them didn't begin this one year ago.
+
+It's to let them off easy, because they're probably stealing \$15,000 yearly. For those of you who don't know, one hundred MA State Troopers have been arrested since 2010, forty six of them arrested or implicated for stealing overtime while forging tickets. The Feds also just arrested the head of the MSP union, Dana Pullman.
+
+The MSP hired Leigha Genduso years ago, an admitted drug dealer, perjurer, and money launderer, with her past criminal actions and acceptance on the force tying into all I've reported since 2010! Below is a story on the MSP hiring Leigha Genduso who had a long term relationship with a LT Colonel! That's okay with them providing she doesn't report their corruption as I do.
+
+http://www.bostonherald.com/news/columnists/howie can/2018/02/carr life of cri me you can be a trooper
+
+So think about it, over 20 years chasing me around, but just as many years working for and with the below wealthy man (Wm. O'Connell) who was arrested for child rape and cocaine trafficking. This child was killed one week before her trial was to begin so he got off, but the MSP swamp isn't looking his way because I'm much more important to them.
+
+O'Connell is tied to the BNEG Nightclub and restaurant group which Joe and Ed Kane own. He's also closely tied to the MA politicians who still do business with him. BNEG has a brother who is a SGT on the MA State Police named Charlie Kane who I personally know and socialised with.
+
+This wealthy and influential group, including rapist and cocaine trafficker O'Connell, appear to have their own private police force protecting them and the same force after me. O'Connell is one of the Kanes top guys and below you'll see how they do business together. He's bad news and so is this group of rogue troopers. The only folks who don't believe he was involved in the child's death are his friends and these troopers.
+
+Below, you'll also read about the corrupt attorneys who work with the troopers.
+
+This document is about the little girl and the wealthy man whose family seems to avoid jail time, avoids thorough investigations, and scrutiny of his crimes due to his political affiliations and wealth.
+
+On April 15th, 2018 this document was sent to FBI offices outside Massachusetts, Washington DC, and several other people I felt would stand for this child and look into O'Connell and the child's death. I've sent it to Boston as well. (They have now retired)
+
+This document is to show who the members of this 'enterprise' of police are, including those MSP are loyal to, a wealthy child rapist and cocaine trafficker, while they harass me year after year and make up excuses why they are doing so. They've done this since I divorced their co-worker.
+
+O'Connell, is a man tied to a few 'untimely deaths', as well as rape and drug charges, including the death of his friend under his boat propellers, murders by others in his family, a woman killed and buried, his son shot a US Marine and only got seven months, and O'Connell is one who the MA authorities refuse to investigate or surveil.
+
+O'Connell was raping a child and arrested for cocaine trafficking, yet he's Trooper Charlie Kanes buddy who apparently knew about O'Connell and his child victims. (this is explained below).
+
+The question is why does L.E. refuse to do their jobs and investigate the many horrific crimes against women and children, MSP crimes against humanity, or the massive government fraud driven by greed taking place by MA police and attorneys? I've already done all the footwork, and have submitted their paper trail, so the rest should be simple.
+
+I've quoted this good male police officer in the past and I will quote him again today, because he can say in a few words what takes me thirty pages to say. He is one who knows what they've done to me since I separated.
+
+"THERE have long been whispers of prevalent sexual harassment in the law enforcement industry, but none have dared come forward with public disclosures. Given the exhaustive debates since the #MeToo campaign began, one would expect considered responses. Instead, it is dispiriting to witness many within the industry peddle the same tired tropes of shaming and blaming victims, and assumptions that sexual predators can be easily discerned.
+
+It is ignorant to pretend that conditioning and social pressures have no effect on victims' ability to speak out, that sexual harassment cannot intersect with other disputes, or that 'hard working family men' are precluded from scrutiny. Abuse of power in law enforcement is particularly insidious given that informal work conditions are taken by some as a licence to exploit. For better or worse, the public looks up to police who, as such, have a civic responsibility to send the right signals. Being called out is not enough.
+
+Sorely needed is an elected body of representatives and outsider experts to draw up a code of conduct and audit productions. Amending harassment legislation to grant the federal ombudsperson suo motu powers to investigate and arbitrate such claims would also show that harassment in any quarter will not be tolerated and will be followed by serious sanctions. For too long, in the absence of accountability and
+
+restorative justice, women's experiences of abusive men have either been hushed up or relegated to 'whisper networks'. The industry must make it clear that, when women do speak up, their voices will be heard."
+
+#### BILL O'CONNELL Both Protecting and Protected by the CORRUPT
+
+#### SOUTH SHORE SEX and DRUG KINGPIN
+
+My name is Lisa Kenney and for almost nine years I've been reporting abuses and corruption by several MA troopers who are seemingly involved with bank, grant, and healthcare fraud, connected to pharmaceutical companies, doing business with unethical attorneys, nightclub owners, and construction companies, and their obvious money laundering.
+
+I had been married to a trooper who I lived with for twenty years, and I dated one of the most corrupt and vindictive troopers mentioned below. I ended that 'friendship' due to his odd, vindictive, and egotistical behavior. His name is Troope
+
+It seems no one in Massachusetts wants to investigate this group and excuses are made up as to why they are not. "There isn't enough evidence" is said, although I've sent almost their entire paper trail on their laundering, federal grant fraud, real estate, and bank fraud which O'Connell is a part of.
+
+In order to get more evidence someone has to investigate and it's been proven MSP never investigated their own! I'm asking that this young rape victims sudden death be investigated because her sudden death is highly suspect, and the only folks who don't believe O'Connell was behind her death are the LE and politicians connected to him, those who accept his donations, and who are friends with him.
+
+O'Connell would pay multi millions of dollars for others to look the other way and he is one of the civilians funding the troopers on the side to try to silence me. I've received numerous death threats, rape threats, threat to be "shot in the face and head", and two separate men have tried to force me into a guard rail on the highway. I have submitted these plates in the past. (See my Denise Robert doc, a FBI unsolved murder)
+
+L.E. frequently asks the public for tips or help when crimes are committed and I've supplied a lot more than tips. These are excuses for an unwillingness to do their jobs or
+
+investigate their friends, either that or it's due to reelection issues. (As it turns out, it just may be and that document has recently been sent)
+
+People are being abused and there's hard evidence children and women have been raped and exploited, along with government grant money stolen. Today, I am focusing on the top wealthy civilians who the corrupt police and attorneys are loyal to and all are protecting one another.
+
+I've sent thirty or more letters on this to former Director James Comey of the FBI and the FBI in Massachusetts. No response from them, but I've received more abuses from the corrupt I've been reporting.
+
+Over the years I had been searching for a specific civilian who is tied to and heading this group with the nightclub owners Kanes of Big Night Entertainment (BNEG), and I believe I've now found him.
+
+Based on what I've found over the years, I allege this 'enterprise' is laundering millions of dollars offshore, including stolen federal grant money, and bringing it back in via real estate and mortgage/financial companies. The attorneys deal with the legal loopholes of this while the wealthy nightclub and business owners launder the money through their many companies. This information can be found on my BNEG and Donor Racket document.
+
+https://docs.google.com/document/d/1VYOZS37PeliAQOkbP75iivcxwg UOCDlytuMks Neh8/edit?usp=sharing
+
+Seven years ago, one of these police officers was online writing to the other police and he told them;
+
+"The person you REALLY work for drives his yacht to the Caribbean during the Winter, has an indoor swimming pool," and he gave a couple more hints as to who he was without giving his name. I believe they said he also owns a bakery but I'm not positive.
+
+Someone in their group deleted this statement just after I found it on a website where they frequently communicate with one another. This is the same site Trooper Charlie Kane was posting his own writings about me which I have sent in the past. Since they have been hacked into my pc for years (per Computer Forensics Associates of Boston), they see all of the information I am obtaining to send to you and delete any evidence I find.
+
+For those new to my documents, I've previously reported their use of online servers to conduct their business and Kane's distribute laptops to members of the enterprise. I've sent this information in the past and I've sent proof they're distributing laptops. In fact, during 2007, and once Trooper Manning was off probation from MSP, he kept sending me emails asking me to tell Trooper Kane he needs a laptop. Manning later hacked my emails and deleted that conversation so I couldn't submit it. The laptop info is shown on my lawyers and courts document.
+
+Based on their comments and other information, I've tried figuring out who this single wealthy person was for years, the "person they really work for" and I believe it is Quincy Developer Wm. O'Connell, the man mentioned above who was arrested for child rape and cocaine trafficking.
+
+O'Connell is good friends with Norfolk DA Mike Morrissey, Rep Bruce Ayers, the Kanes who own BNEG nightclubs, Senators Keenan, Keating, and Senator Brian Joyce, FX Messina, and several politicians including Delahunt.
+
+He's also described as one of the most powerful Massachusetts developers with strong political influence. Most of these politicians' names have already been mentioned in my many letters to show their ties to the corrupt police and unscrupulous attorneys. One being Braintree Attorney Kathleen Morrissey who you will read about below.
+
+Kathleen is tied to the Messina boys who violently drugged and raped my friend, they are more big donors to the DA's office who never charged them with the rape either. All of these wealthy 'donors' seem to get away with their many violent crimes. At the same time of her rape I found these troopers had pay transactions with the Messina boys who raped SK. (I was invited out with her and them that night but declined). The Messina's also want me silenced, and the last time I was in their section of MA, a couple of them followed me around. They're easy to spot because their license plates begin with FX.
+
+Due to his friendship, DA Mike Morrissey had to hire a special prosecutor for Wm. O'Connell for the rape and drug charges. I'd be curious to know if the fire which was in his office destroyed any information on the Messina rape. There was some backdoor settlement with my friend who probably thought it was normal court procedure, and it was probably Attorney Morrissey who scammed her to settle and protect the Messina boys. The Messina's are also connected to Wm. O'Connell.
+
+The two of them are also found entangled in the same drug treatment centers which troopers, lawyers, and some judges are silently running, including Judge Bibaud of the latest MA State Police scandal shown in the link below.
+
+http://www.wbur.orginews/ww/n/antrooper-lawsuit-edit-police-report
+
+MA keeps screaming for more "drug epidemic money", yet the major wealthy white drug dealers, one whom I believe to be Wm. O'Connell, his son, or his nephew, are NOT being watched or investigated!
+
+A little background on O'Connell is below and includes his arrest for child rape of He had nineteen grams of cocaine on him at the time of arrest. This is who the rogue MSP and politicians are loyal to.
+
+A couple of nights ago I found information tying him to these troopers and I found plenty of information which shows they were aware of his yearly rape relationship with this fourteen year old girl who he lavished with money and gifts for sex.
+
+They have registered plenty of shell corps and accounts using the fourteen year old girl's name, as well as the adult female named Capuano who pimped her out to O'Connell, a man who is in his seventies. They also used to run online `Sugar Daddy' websites which they were members of. It's possible he met Capuano through the troopers website?
+
+He's probably on the list of names of those who visited Jeff Epstein when he "drove his yacht to the Carribean". They do have Ghislaine Ebay accounts. Check them quickly, or they'll certainly contact their friends in the law enforcement section of Ebay to delete, alter , or have them reissued to a random person not tied to them!
+
+# rofile
+
+ghislaine55 (276 )
+
+Positive Feedback (last 12 months): 100% 0
+
+Member since: Dec-01-03 in United States
+
+I believe Capuano who pimped the child out has since run off to Brazil and they would give plenty of money to get rid of her.
+
+Don't think she's the only victim either, but she is the only one who had the courage to file charges against him, and yet, the police refuse to keep an eye on him.
+
+There is a child rapist running free and let's not fool ourselves to believe she will be his last victim. If MA doesn't care about protecting children I will find someone who does. Grave crimes are being committed against women and children with law enforcement not only looking the other way, but defending and protecting them.
+
+O'Connell has many million dollar homes in several locations with a few being Quincy, Marina Bay, Chappaquiddick, Florida, and I'm sure one of his many homes has an indoor swimming pool as the police had mentioned online.
+
+He does have a yacht and a forty-seven foot cigarette boat named `Thunder-Enlightening,' and I've provided a matching Ebay account with this same name which I believe is owned by a trooper and part of this enterprise.
+
+If he is paying them for services, women, children, court outcomes, or business favors, they'll pass money via Paypal & Ebay. This is also a way kickbacks and political donations are distributed between these cops and attorneys. I've collected twenty million of their transactions since 2010 SO I can identify them easily.
+
+As you can see below, the account using his boat name holds 226 transactions and these will be transactions connected to O'Connell and the police ties to him. The transactions could be tied to his construction co, his nightclubs, or the little girls he raped.
+
+KEEP IN MIND, I sent this information in a few years ago, so they've had plenty of time to get their Ebay friends to alter or cancel and reissue the below account name. They do this ALL the time to protect the original owner of the accounts they don't want connected to them! I've seen it happen with all the important accounts which expose them.
+
+thundernlightening ( 226) 17 years 3 months PA,United States
+
+I'm going to deviate from O'Connell for a moment, because I want to show you one of their connections to a judge and a drug treatment center tied to the courts.
+
+You may have read about MSP Colonel trying to protect Judge Bibaud and his daughter from embarrassing facts regarding her arrest, there is also Judge Estes who appears to be a part of this group of police, wealthy, and unethical attorneys. Both of them are also tied to drug treatment and healthcare networks, the same treatment and healthcare this corrupt enterprise, including Attorney Morrissey, and the DA are a part of.
+
+The link to the story is below.
+
+http://www.gazettenet.com/Former-Eastern-Hampshire-District-Court-judge-engagedin-willful-judicial-misconduct-that-brings-the-judicial-office-into-disrepute-th4o63o9
+
+Now I will show you the connections between them (Judge Estes, the rogue cops, and attorney Kathleen Morrissey), as well as their ties to the healthcare network which they are running using fictitious names.
+
+This is yet another treatment center facility this group is connected to which is receiving federal grant monies. I've sent plenty others to the FBI in the past and showed they've received multi-millions in awards while using fictitious names.
+
+In this case, Judge Estes was having sex with a court social worker from the Behavioral Healthcare Network the cops and lawyers run. Attorney Kathleen Morrissey is using another one of her aliases on this healthcare network, this time she's using Katherine Wilson and has signed the documents as such. I've provided one of her Wilson signatures and screenshot from the healthcare network below, as well as her legal signature for you to compare.
+
+To break it all down for you, I've provided the link to their fictitious names shown on Behavioral Healthcare .
+
+SAMHSA and BHTCC have to do with federal grant awards as explained on their website.
+
+I've also supplied the cops and lawyers Ebay accounts for both these grant names of Samhsa and Bhtcc, and I've supplied the cops Ebay accounts they've created using the same fake names found under the center's leadership.
+
+The Healthcare Network Website and leaders who are really this group.
+
+https://bhninc.org/aboutileadership/president-and-ceo/
+
+Below are a couple of the troopers Ebay account names using this same healthcare network where they hide behind fictitious names.
+
+#### BHTCC -grants
+
+bhtc ( 182) 17 years 0 months Germany
+
+#### SAMHSA -Funded Grants
+
+samhsa ( 31) 13 years 8 months MD,United States
+
+Below is Attorney Morrissey using an alias of Katherine Wilson, the screenshot shows her signature from the Behavioral Health Network and it doesn't take an expert to see they are identical to her legal signature taken from court documents.
+
+Her alias of Wilson is displayed first.
+
+Morrissey is also connected to Wm O'Connell and all of the above engage in these activities together and have for over twenty years. She is also tied to the Messina's who raped my friend. This is shown on the sexual assault document.
+
+![]()Below is the Kathleen Morrissey legal signature from my court documents when she represented my ex husband. The signature is a little messier than how she usually writes but it's hers.
+
+![](_page_16_Figure_17.jpeg)
+
+BHN is for Behavioral Healthcare Network and the next three Ebay accounts represent the listed leadership of this center, but they are all police officers using fake names. Swittenberg is a name taken from BHN.
+
+[bhn](#) ( 70 )
+
+19 years 10 months TX,United States
+
+[swittenberg](#) ( 6 )
+
+6 years 6 months NJ,United States
+
+Back to O'Connell..
+
+A special prosecutor or investigative agency from another state is needed to investigate MA, O'Connell and the rot of society posing as police officers. Law enforcement ignored all of the rape and death threats which were sent to me via email and also directed at my minor daughter.
+
+Since they're hacked into my pc, they can see the information I've been compiling and typing on this document. Rest assured, they will run to O'Connell and tell him what I am reporting which they've already done in the past with others.
+
+The reason they do this is because the dirty cops make money off me. O'Connell and the other wealthy I've been reporting pay the rogue law enforcement big money to chase me around on the side with hopes they'll be able to silence me or stop or block my complaints.
+
+In order to silence me, you have to follow me around to see where I am, where I'm mailing or faxing from, or if I'm at a public location sending emails.
+
+This has already been proven, both their hacking and their intercepting my letters. I have signed signatures from the AG and DOJ my letters were received, but when I call to inquire they have "no record" of them.
+
+Bill O'Connell is shown below. Does anyone find the below " accident" suspect? His rape victim returns to MA to prepare for trial and is suddenly killed in a "fiery car accident". If it didn't sound suspicious to you before, perhaps it will after you read this?
+
+![](_page_18_Picture_0.jpeg)
+
+SOURCE: Greg Derr/Patriot Ledger
+
+QUINCY, Man. — Less than two years after William O'Connell was charged with having a sexual relationship with a 14-year-old girl, and three months after the girl was killed in a fiery car crash, the wealthy Quincy developer is likely to walk out of court friday a free man, our news partners at the Patriot Ledger reported.
+
+A prosecutor and lawyer for O'Connell will present a plea agreement to a Norfolk County Superior Court judge that drops all charges against O'Connell, including four statutory rape counts and a cocaine-trafficking charge.
+
+"http://www.wickedlocal.com/x767231206/Wealthy-Quincv-developer-Wilham-O-Con nell-charged-with-child-rape-cocaine-trafficking
+
+A little more on O'Connell and his sons is below..
+
+Keep one thing in mind while reading all of this, they know I've been collecting this information for years so they've had plenty of time to discard their hard drives, get new cell phones, close places they've held illegal `stings', and destroy evidence. This is one reason they are still hacked into me, it's to protect, destroy, and prepare to discredit my findings and reports. They also have many attorneys coaching them behind the scenes.
+
+O'Connell, a man who was convicted of multiple felonies, but a man who has money and ties to politicians and law enforcement, coupled with LE's priorities tied to elections, their political party, and a group blinded by greed, makes for a failed government and sham democracy.
+
+I'm going to be showing more of O'Connells ties to the rogue troopers, the ICanes, and their ties to the escort business. What better way to protect the wealthy men, the wealthy married men, married police, politicians, and the paid escorts than to have police run the show?! They are able to protect both the john' and the escorts since they're usually the ones responsible to arrest them.
+
+There's one trooper I consider to be a sexual predator who has boasted about women deserving to be raped, lives at strip clubs when he's off, supports rapist Messina who raped my friend 'S', and he films unsuspecting women undressing, in the bathroom, and having sex. He's also posted numerous photos of naked women in their bathrooms on Craigslist and titled the photos 'Peeping Tom'. His name is Trooper David M. Manning whom I dated a few times and ditched.
+
+In fact, he tried forcing me to have sex with him by holding me down, until I got angry and threw him off me so nothing else happened. He is the one currently sending ex-cons and criminal informants to harass and commit crimes against me in NH.
+
+Years ago, one of the troopers told the others online "If I go down I'm taking everyone with me" and I'm pretty sure it was Manning who wrote that. This is the reason I feel they haven't held him accountable or even responded to my hundreds of letters about his crimes against me and my child. Manning was a part of their group long before he got on the state police because he probably worked for one of their nightclubs. PI Bob Long is one who is a part of this 'enterprise' because Long works for these same wealthy folks.
+
+#### Facts on the O'Connell Family
+
+William O'Connell was charged with raping a fourteen year old girl for years and was charged with cocaine trafficking. He gave her cash and allowed her to use his credit card to purchase thousands of dollars of goods in return for sex. Child was killed one week prior to the onset of his trial.
+
+William O'Connell was given six months probation after being charged with negligent motorboat homicide in 2002. O'Connell's best friend, William Sanderson, 62, of Quincy, was killed when he was struck by the propellers of a boat with O'Connell at the helm off Chappaquiddick Island. A charge of drunken operation of a boat was dismissed."
+
+O'Connell was charged with assault with intent to murder, assault and battery with a dangerous weapon and unlawful discharge of a firearm.
+
+O'Connell listed his occupation as a real estate developer with Marina Bay Development in a report filed earlier this year with the state Office of Campaign and Political Finance. There may be ties between him, Epstein, and Granite Reality.
+
+He and his extended family have given thousands of dollars to local Democrats, politicians, and candidates over the years, including to U.S. Rep. William Delahunt, who lives at Marina Bay, and Treasurer Tim Cahill, also of Quincy.
+
+This is not the first time that the extended O'Connell clan has run into trouble with police. Robert O'Connell's cousin, Matthew "Ky" O'Connell, was convicted of second-degree murder in the 1987 stabbing death of Julie Hamilton, 22, who grew up in Randolph. Hamilton's body was found in a shallow grave in a wooded area about 100 feet from the house where Matthew O'Connell was living with his mother. Matthew O'Connell, William O'Connell's son, was sentenced to life in prison with the possibility of parole after 15 years.
+
+The articles on his arrest and long term rape of a fourteen year old child is below.
+
+http://www.patriotledger.com/article/2012122o/NEWS/312209226
+
+https://www.bostonmagazine.com/2on/o9/27/fast-times-at-marina-bay/
+
+http://www.patriotledger.com/x1444028051/High-profile-Quincy-family-at-center-ofattempted-murder-case
+
+O'Connell 74, crashed his helicopter while entertaining two women in their twenties. The troopers even created Ebay accounts under the womens names.
+
+https://vineyardgazette.com/news/20o8/06/23/helicopter-crashes-lake-tashmoo-no-i njuries-investigation-continuing
+
+O'Connells son was arrested for shooting a US Marine and firefighter during a road rage incident. O'Connell got off as the firefighter 'decided' to not press charges.
+
+BNEG and O'Connell own nightclubs and restaurants next door to each other and have worked together for years. There seems to be lots of deaths surrounding O'Connell and his family and they always seem to get no real punishment or prison time.
+
+Due to the sudden death of his young victim, O'Connell got off.
+
+When arrested O'Connell had nineteen grams of cocaine on him.
+
+Where did he get the large amount of cocaine? His sons? Do police watch them ? No, they do not. All law enforcement should know major dealers have 'safe houses'. Did anyone do any checking on the abandoned Quincy apartment where they found millions of dollars worth of cocaine and cash?
+
+Guess who's a part of that complex? Bill O'Connell is!
+
+A man named David Max Aaronson grew up near him and was arrested in 2008 for cocaine trafficking. I later noticed he was online with the troopers when he posted a photo of his stomach tattoo while communicating with them. He could be one of O'Connells Quincy drug dealers as well.
+
+Most of their business is done online to avoid a footprint of their communications and dealings. This is how I'm able to find them.
+
+I'd like to add that I believe there is more to the sudden death of the child rape victim which I'll explain below. There are many people who feel her death ou e proper y investigated, especially since we know O'Connell will continue preying on young girls due to his protection.
+
+This group will lead you to one of the major drug dealers in MA which for some reason law enforcement doesn't seem to be in a rush to find them.
+
+Perhaps the dealer IS O'Connell or his sons?
+
+This group was well aware of O'Connell's relationships with these girls, minors, and escorts, and yet they still referred to him as their 'real boss'.
+
+I can also provide many of their Ebay accounts and shell corporations which were created under the woman involved with the Resendez girl, including the Malden officer who investigated her death and the fiery crash.
+
+There was an Ebay account they created under the investigating officers name at the same time Rebecca returned to MA to prepare for trial. According to online news networks, the officer who investigated her death is Captain Gatcomb of Malden PD who was a detective at the time. When I contacted the PD involved they wouldn't respond to me because the MA troopers told them to ignore me.
+
+I've provided the Gatcomb Ebay below. Again, he is the one who investigated the girls 'accident'. Someone placed a 'B' in front of his last name and I don't know if that is for Bill (O'Connell) or the troopers who use 'B' a lot online as a reference to their group. (I have monitored their online dealings for twenty years)
+
+If this is the investigating officers Ebay account below, then it should raise suspicion of both her death and the investigation of the accident. If it's a troopers account, it's also highly suspect due to their business and friendship ties with O'Connell. I'd be willing to bet O'Connell would pay millions to make his statutory rape case go away.
+
+Why was the rape victim driving a car she wasn't supposed to be driving, and is the owner of this car affiliated with the Phyllis Capuano girl who pimped her out to O'Connell?
+
+Were accelerants found in the vehicle? I'd be willing to bet no one searched for them, and I'd be willing to bet the car can no longer be found.
+
+Did anyone find any connections between the vehicle owner and Capuano, O'Connell, or any of his many construction businesses tied to the area where she lived or crashed ?
+
+I'm sure one of O'Connells employees had ties to either the rape victim, Capuano, the car owner, or some of their family/friends. O'Connells reach is far and wide but I'm sure the ties can be found. Did anyone look for them?
+
+My auto smelt of gas for a few days during the time two separate men were sent to try and force me into a guardrail on 93. I've since sent in their license plates.
+
+Was there really a passenger in the vehicle with her and how did she escape slightly injured if the car went airborne and burst into flames? O'Connell would also pay a lot to say someone was in the car with her as a 'witness'.
+
+One of them threatened me during 2O11, they said " we pay a lot to get what we want" and I still have this on email.
+
+Did this passenger see anyone try to force to crash, or when she lost control of her vehicle before the crash ? NO, because it happened at 330 AM when most are asleep.
+
+I find it highly odd that during 2012 arrived back in MA, finds a car she wasn't supposed to drive, is immediately killed, and at the same time, these troopers connected to O'Connell created an Ebay account using the investigating officers name!
+
+All of the above happened one week before the trial, the child was suddenly killed, and O'Connell got off and avoided the rest of his short life in jail.
+
+I've checked all Ebay accounts including bgatcomb, billoconnell, and thundemlighting, and all three of them appeared to have been altered. So, someone is covering something up.
+
+An easy way to cover who owns the accounts is to have their friends at Ebay cancel the original account and have a random person recreate another using the same name.
+
+This way the original owner is hidden and protected.
+
+Below is the Martin Luther King Health Center where you can see the name `Dare Johnson' and Bill O'Connell. I submit these few shells simply to show the police are connected to him, and the Dare Johnson will belong to a cop.
+
+These cops have created over 250,000 shell corporations for these wealthy and nightclub owners, many of which are tied to the corrupt attorneys close to them. I believe they've also altered the below account.
+
+darejohnson (12) 4 years 6 months LA,United States
+
+![](_page_24_Picture_3.jpeg)
+
+As I've done in the past, I can match all the above names on the shell with the MA cops Ebay accounts..
+
+Bill O'Connell referred to the little girl who he raped for months as 'Kookie' which is also a name his friend Trooper Charlie Kane texted to me during 2008.
+
+For Charlie, this was a reference to his friend 'Mathias' who accompanies the troopers on illegal stings where they have sex with women and secretly film them.
+
+This is the reason Trooper Kane texted the name 'Kookie' to me, because he's friends with O'Connell who probably calls all of his paid child rape victims 'Kookie' so he doesn't have to remember their names.
+
+After I fought with them is when Charlie sent me the text.
+
+Trooper Kane and O'Connell are very dose, and during 2008 (and years prior) Manning was spreading rumors about me that I was a prostitute. The Kookie text from Kane wasi a reference to that rumor. But, the fact of the matter is that Trooper Kane knew about O'Connells many child victims he called Kookie, and that's why Kane texted me the same name.
+
+A person named Jane Debo also tried luring me to Wm O'Connell's golf club but I declined. Jane was recruited by these troopers who told her to do so, but I have no idea what their plan was at the time.
+
+A man driving a BMW once approached me on a Quincy beach and made sexual comments to me. He also knew things about me he shouldn't have known unless the troopers sent him. Looking back today, after seeing his photo, I believe that man was Wm. O'Connell.
+
+O'Connell and his sons used their various construction company license numbers for their Ebay accounts as well, with all transactions between cops and the Kane Enterprise. I haven't provided these today but have provided them in the past. Below may be one of them, and when there is only one transaction on an Ebay account, it means a large amount of money has been passed.
+
+One O'Connell Ebay account is shown below and originated around the time of the girl's death.. Since this document was typed a few years ago, that means the below account is actually over ten years old.
+
+billoconnell ( 1 ) 4 years 11 months Germany
+
+The first account shown below, O'Connell has transactions with all the troublemakers including bdubia, which 'may' be Internal Affairs Dave Debuccia who is a part of this corrupt enterprise. DUB IA
+
+oconnel ( 286)
+
+bdubia ( L3t4)
+
+dubia ( 20Q)
+
+18 years 11 months NJ,United States
+
+18 years 7 months
+
+15 years 11 months
+
+PA,United States
+
+Germany
+
+Thunder n-lightening is O'Connell's cigarette boat name. The Ebay account is below and the pay transactions can be for anything.... women, drugs, fuel, jobs, cover-ups, or court outcomes, etc. The point is the transactions are with troopers using O'Connells boat name and dates back almost twenty years. They have been doing business with him for over twenty years.
+
+thundernlightening ( 226) 17 years 3 months PA,United States
+
+Kookie is the child rape victims nickname O'Connell called her.
+
+ckookie ( a ) 16 years 3 months United States
+
+Mussaw was the last name of one of the women with O'Connell when he crashed his helicopter.
+
+mussaw( 43) 17 years 1 month MD,United States
+
+Malden Police Detective Gatcomb investigated her accident and claimed "no foul play", but if this is his account, he has transactions with the biased troopers who are friends with Bill O'Connell, thus another conflict of interest, or cover up.
+
+I was also told MSP took over the investigation of her death, but they'd never tell me because they know I will find his Ebay accounts and ties to them. MSP usually uses their names and four digit MSP ID numbers, and many times place a MA, S, or SP before their ID numbers when creating their accounts.
+
+Trooper Charlie Kane uses Maine on his accounts as he has close family living there, so this Gatcomb account could belong to him as he is a close associate of O'Connells.
+
+The name Gatcomb is the name of the officer who investigated the little girl's death. I find it suspect this account was created at the same time she returned to MA and at the same time was killed.
+
+If Trooper Kane owns it, he is close to O'Connell and texted me to call me Kookie, just as they called Capuano. He's also at the top of the rogue donor group and one who moves the big money around.
+
+As I stated above, to cover up their connections and crimes, they've been duplicating Ebay accounts to hide the original owner, and they have friends working at Ebay to assist with this.
+
+So, I'm wondering why the account below no longer shows it's location in ME? It's usually because it was tampered with. So, let's say Bill O'Connell didn't want the child's death appropriately investigated, and he wanted to pay Gatcomb off to cover it up. Since he trusts the head of this rogue group Trooper Charlie Kane, he would pay him the large sum of money and Kane would open an Ebay account under Gatcomb's name. The payoff would then be passed.
+
+They would go to great lengths to cover something this big (if they did). I've provided the screenshot to the account I just found. The original account shows Maine and is older than it appears below.
+
+If the ME account was connected to the troopers and the cop who investigated the little girl's death, that would be why it was changed.. The account was created once the child victim arrived back in MA.
+
+The one I just found is below and no longer shows ME as the location which I find suspect. To alter an account to hide the original owner, they will ensure the member name, member date, and number of transactions match the original account. This seems to be happening with all the accounts they don't want to be connected to.
+
+.mmunity > Feedback forum > Feedback profile
+
+# )ack profile
+
+bgatcomb ( 21 \* ) Positive Feedback (last 12 months): 0% [How is Feedback percentage calculated?) Member since: May-02-12 in United States
+
+I'd be willing to bet O'Connells trooper friends were illegally listening in on the girls conversations while she was in California, just as they did to me for years, and heard she was coming back to Malden.
+
+They also do this to get first hand knowledge of private meetings between attorneys and their clients if they are involved.
+
+Listening in on her private conversations would give hints as to how he may beat the case, the specific evidence they have, and sensitive case information about him the child shared with the attorney.
+
+Most importantly, he would find out exactly when she was coming back to Massachusetts. She came back and was killed.
+
+They engage in fishing expeditions and illegally gather evidence to protect their illegal organization and members. They also knew the contents of my conversations with my attorneys after they had me falsely arrested in order to silence me. (I was found not guilty).
+
+The below corporation is from his Marina Bay management Co. They also have accounts under its address. I believe Peter O'Connell is his son and the one who shot a firefighter during a road rage incident. He also got off attempted murder charges.
+
+#### ARTICLE WI
+
+The effective date of organization of the corporation dull be the date approved and filed by the Secretary of the Conunonweaki. If a later dtecove date is desired. specify such date which dull not be more than retry days after the date of filing.
+
+#### ARTICLE VIII
+
+The Information contained In Ankle VW S not a permanent part of the Ankles of Organizadion.
+
+a. The street address (post office bare are nor acceptable) of the principal office of the corporation In Massachusetts it
+
+Quincy, MA 02171 b. The name. residential address and pOSI office address of each director and Officer of the corporation is as follows.
+
+NAME President. Williaa S. O'Connell Trasanal Willian S. O'Connell aerk Richard C. Pierce Directors. William S. O'Connell Richard C. Pierce Walter J. Hannon, III IISIDENTLU. ADDRESS POST OFFICE ADDRESS Miramar, FL 33023 Mira ,i 1.3302 Randolph, MA 02368 Quincy, MA 02170
+
+Vita
+
+I
+
+As you can see, Hannon is another name on O'connells business but these accounts are all owned by cops.
+
+hannon ( 8'7) 19 years 11 months MD,United States
+
+FEDERAL I.D. NUMBER
+
+04-2517835
+
+CERTIFICATE OF CORRECTION  
+(GENERAL LAWS, CHAPTER 156B, SECTION 6A)
+
+CORPORATE NAME: O'Connell Management Company, Inc.
+
+DOCUMENT TO BE CORRECTED: Massachusetts Corporation Annual Report for year ending December  
+IT IS HEREBY CERTIFIED THAT THE ABOVE MENTIONED DOCUMENT WAS FIELD WITH THE OFFICE 31, 1987  
+OF THE SECRETARY OF STATE ON 11/01/98.
+
+PLEASE STATE THE INACCURACY OR DEFECT TO BE CORRECTED IN SAID DOCUMENT, AND THE  
+CORRECTED VERSION OF THE DOCUMENT:
+
+The correct names and addresses of all officers and directors of the corporation  
+are as follows:
+
+President - Gary S. Grimes, [REDACTED] Scituate, MA 02066  
+Treasurer - Linda R. Golden, [REDACTED] Quincy, MA 02101  
+Clerk - John W. Sharry - [REDACTED] Quincy, MA 02171  
+Directors - Peter F. O'Connell, [REDACTED] Quincy, MA 02170  
+William S. O'Connell - [REDACTED], N. Quincy, MA 02171  
+All shall serve until successors are duly elected and qualified.
+
+IN WITNESS WHEREOF AND UNDER THE PENALTIES OR PERJURY, WE SIGN OUR NAMES THIS 10<sup>L</sup>  
+DAY OF January IN THE YEAR 1989.
+
+X Gary S. Grimes PRESIDENT/VICE PRES.  
+John W. Sharry CLERK/PRESE - CLERK
+
+NOTE: IF THE INACCURACY OR DEFECT TO BE CORRECTED IS NOT APPEARED ON THE FACE OF  
+THE DOCUMENT, MINUTES OF THE MEETING SUBSTANTIATING THE ERROR MUST BE FILED WITH
+
+Their president is listed as Gary Grimes but transactions on all of these accounts are  
+with troopers and this corrupt group.
+
+garysgrimes ( 19 ) 15 years 3 months OH, United  
+States
+
+johnsharry ( 111 ) 9 years 6 months OH, United States
+
+golden ( 140 ) 14 years 6 months Germany
+
+After going through many of O'Connells business names, locations, folks he's connected to, employees, and all of the false real estate listings created for him by police, I know he is the one they were referring to as the "person they really work for".
+
+I could list all of this for you but you're looking at another fifty or more pages. I've done it plenty of times in the past so you know I can obtain it easily.
+
+Two days ago I found one of the troopers bogus Facebook accounts. The name of it was Kane-O'Connell and all of his FB friends were these police officers using their known aliases. Overnight, someone remotely hacked my pc and deleted the screenshots I took of this account, so I'm sure they also deleted the Facebook account. This is what they do to hide the truth.
+
+I'm going to show some of the erotic women information I've found over the years which is tied to them and which I've reported to all MA investigative offices and James Comey.
+
+Think about it though, had you investigated all I've told you since 2010, their escort ties and the Mathias incident, my friends rape, this little girl may have never been victimized and may be alive today, but Mass. LE chose to ignore me.
+
+#### Facts and ties to escort services and sex workers.
+
+O'Connell- paid a fourteen year old girl for sex over a period of years. He was also convicted for cocaine trafficking and there are several sudden deaths and attempted murders involving him and his family members. Trooper Kane, Coletti, and Manning work with him. He's friends with Norfolk DA Morrissey.
+
+Messina's- Drugged and gang raped my friend 'S' analy during 2006. She told me who did it but they were never charged. They are also wealthy developers and do business with Trooper Kane, Coletti, and Manning. Messina's are friends and donate heavily to Norfolk DA Morrissey where Trooper Kane was working. Attorney Kathleen Morrissey is also close with them. I was invited out with them that night but declined. Messina was approaching me at the gym during the same time Trooper Charlie Kane was.
+
+Mathias- A civilian who assists the troopers on police stings where they illegally detain women, film them, and have sex with them. Trooper Manning does the filming and then distributes it while protecting Mathias' identity. Mathias is friends with Manning and Kane and he's either a lawyer or the excavator in Kingston. He is also always on Craigslist with them advertising for women. Mathias was seen at the Kane clubs with Trooper Charlie Kane.
+
+Mathias posted a photo six years ago which was found on one of their many 'hooker' sites. This photo consisted of several women in black dresses. As soon as I found the photo and saved it, they deleted the site and the photo. It had his name on it and is shown below. I believe these illegal stings of the private investigators, their 'Sugar Daddy' websites, their many trips to strip clubs, silent owners of some, and their advertising on Craigslist for women to strip for them, are to screen women for their own escort business and the VIP tables at Kanes nightclubs.
+
+![](_page_32_Picture_2.jpeg)
+
+This photo was taken from their 'Mathiasparis' club website, a site which offers a bottle of grey goose for \$300.00.
+
+I have submitted at least fifty of their Mathias accounts recently. Most were out of 'Germany, but the troopers use Germany.
+
+I've submitted their many ties to strip clubs in both MA and RI. I found Kane to have all the club ties but O'Connell owns some as well.
+
+During 2008 and years after, the troopers used to post on Craigslist seeking attractive strippers to entertain them at private parties on the South Shore.
+
+I've submitted the rape threats they sent to me as well as rape threats directed at my fifteen year old daughter. There was no response from MSP or any MA law enforcement, including Maura Healey's Office.
+
+They're tied to Tom McCready, a Norwood bartender who drugged my drink years ago. I left the bar before it hit me so nothing happened to me. The bar where he worked could be owned by friends of theirs, or even Bob Long, but the connections are there. They are silent owners of many businesses. I know I was drugged because I only had two beers over a five hour period and felt fine before I left. McCready was the only one who served me the two beers, and kept asking me "how I was feeling" before I left. (He asked me at least six times) See Predator Cops document.
+
+During 2009, Jane Debo of Braintree, a woman who the troopers recruited to target me, tried luring me to O'Connells Granite Links Golf Course in Quincy for drinks.
+
+The cops have registered shell corporations for the wealthy under the names of the young rape victim, the nickname O'Connell called her which you can read in the article (Kookie), and Capuano. (The woman who brought the child to him) One of their shell corporations is below but they have them in all states. I told you, they're assisting the wealthy with laundering and they need shells to do so. They have over 250,000 of them. KOOKIES INC. is below.
+
+![](_page_33_Picture_3.jpeg)
+
+I hold photos of a cop's wife they placed online. She was stark naked and posed in many graphic photos. The cops swap photos of their wives with one another and post them online. Think about this, if they do this to someone they love', what do you think they'll do to women they don't know, or women they hate such as me? I know about this because I tried getting the photos removed from online.
+
+They had no problem recruiting two registered NH sex offenders of young girls to harass me and assist with stealing evidence from my residences, two of them being Dan Gallant and Kenneth G. Reed.
+
+They had many escort sites which catered to their group. All transactions related to these escort sites were among cops, lawyers, and those connected to the troopers. These were not sites where cops are trying to catch 'johns' or prostitutes and were immediately removed once I located them.
+
+One of their Ebay accounts showed a man complaining about the woman he had an encounter with, and the owner of the account told him "I put them through a two - three week thorough testing before dispatching them".
+
+(I will show you some of the 'sale' descriptions from their escort accounts below.)
+
+Many of their websites referred to underground dub services, VIP's, and offered a variety of women. Some are mentioned below.
+
+One of Kane's nightclub patrons told me a known escort works at his club and the VIP tables are known 'underground' services w/escorts. I also hold VIP Kane and Pimp EBay accounts which I will include but I'm sure they've discontinued them by now.
+
+One of their sites offered underage girls which I reported to the FBI and AG at the time. This would entice someone like O'Connell and I'm sure there are others.
+
+I found a website which sought underage Thai girls which had the Mathias and another wealthy civilian name from NH on it.
+
+They also run or ran a site called 'Sugar Daddy'. They kept sending me the link for over a year before I looked at it. I originally looked at it after reading the weird ads alluding to men requesting to be used by gold-diggers and I also suspected Frank Messina Sr. was a member. It turns out he was, along with his sons who raped my friend, and who do business with Kane and Manning. If no MSP arrests were ever made from this site, it means they ran it to find attractive women to recruit for themselves.
+
+I did interact with someone from this site but not for any 'daddy' reasons, I made fun of him for wanting to be used by gold diggers. This could also be how O'Connell came across some of his women, including the woman who brought a fourteen year old to him. (Phyllis Capuano).
+
+During 2007 Trooper Charlie Kane texted me and asked me to meet him at a condo in Weymouth where he was "house sitting" for a female friend but I declined. They have
+
+many properties and nightclubs; including O'Connells extensive properties to accommodate their women, and as you will read below, the hidden audio and visual devices are included. Kane probably thought I'd meet him and have sex so he could video it, but I've always turned down his sexual advances. (He is married or was at the time)
+
+I've been to their after hours bars in Quincy until 6AM where a trooper was bartending. ICanes night clubs stay open past 2 AM and who is going to do anything when they're that closely connected to the police, Quincy politicians, and O'Connell? I'd check the clubs underground or basement entertaining after hours, but I've been typing this for a week so I'm certain there are clean up efforts taking place.
+
+They were on Craigslist daily and nightly requesting all varieties of women to entertain them. I believe they were searching for women to work for them, because their demand was for all types of women. Asian, young, large women known as BBW's, etc.
+
+One of the troopers made a comment about their erotic women being too expensive so he was going elsewhere.
+
+MSP Trooper LeMar was arrested for going to the prostitutes at Brocktons Aria Salon. The owner of the salon said there were 23 other troopers who bought their services. This could be the cheaper place he was referring to. They have a large amount of 'Aria' accounts.
+
+I read a review of one of Kane's clubs which I believe ended up being shut down. The review stated the person was disgusted watching the nightclubs bouncers frequently taking unknown drunk women home. These were woman who stumbled out of the club and could hardly function.
+
+I'm going to throw out some of their online and known escort names they've used and have created websites under. I'm also going to show you some of their `customers' comments. All of this and more was sent during 2015 to MSP, DOJ, FBI, and AG, and all accounts were active at that time. Today, many accounts have been removed or canceled, but I sent them to all of you in MA who did nothing.
+
+Their hooker and escort club sites had the names Crystal Club, Paris Club, Hub51, and were run by the Mel rian Brothers. Some of their Ebay account names are below and were active five years ago. The melman account was definitely canceled and reissued to hide the original owner! I've thoroughly checked this!
+
+crystalclub ( 13 years 8 PA,United 234) months States
+
+I believe most were canceled as soon as I found them.
+
+In the past I've sent in many of their `peeping tom' and `bathroom' accounts. Some of their pimp accounts are below but they have many alluding to sex for money.
+
+apimp ( 52) 14 years 5 months Germany
+
+Just like their Kookie shell above out of MD, so is their Ebay account.
+
+vippimp ( i2 years 10 MD,United 53) months States
+
+escort ( 11) 14 years 6 months Germany
+
+pimpo ( 23) 4 years 0 months Switzerland
+
+One of these cops sites also hinted about their facility being in the "Red Light District" and they claimed it's their private "underground" club, which is probably a Kane or O'Connell club. Basically, their websites are disguised as upscale clubs and restaurants which offer VIP packages costing thousands of dollars.
+
+On these sites, take a closer look at the 'restaurants' thousand dollar packages, and you will see women's physical descriptions who are labeled by class, bra sizes, and the more expensive package claims they will equip you with " all of your audio and visual needs".
+
+Some of the tables at the Kane Clubs exceed \$5,000.00. Most of their accounts have now been deleted after I sent it to the FBI ,DOJ, AG several years ago.
+
+According to their website, the business package' offers "complimentary audio and visual with wireless microphones" and I've sent all of this to LE in the past right from these websites!
+
+This sounds similar to the Kanes Grand Nightclub and their offerings, but their erotic offerings are online only and disguised under various fictitious club and restaurant names.
+
+I'm certain the online phone numbers one would call from these sites to reserve a table would have been tied right to those at the Kane Clubs. (I have sent all of this information in depth years ago, and since then one of the corrupt has gone into my emails to delete all of it. )
+
+All transactions on these accounts are between cops, lawyers, wealthy, corrupt, and all men.Again, because I typed this years ago, the below accounts are older than they appear, but I'm sure have been tampered with.
+
+redlights( az)
+
+at ( i8)
+
+4 years 2 months
+
+13 years 1 month
+
+"THANX SO MUCH FOR SHOPPING AT PRO STREET, WE APPRECIATE YOUR BUSINESS! XX"
+
+The group of men offering these women for a price went by the name Melman Brothers. Several years ago I pulled his account which originated during 1998. Today, I pulled the account again and they've had someone recreate the Melman account to hide the original owner who created the account during 1998.
+
+The new one is below and this is one way they are hiding their misconduct.
+
+You want to find the owner of the original account, the one I copied and pasted from Ebay over 17 years ago.
+
+The original account is out of CA and the newer one is out of TX.. Melman was one who claimed to run the "underground club". You can see below one of the cops recreated it, it was to hide the original owner, and there is a good reason why.
+
+melman ( 8 ) 1 year 11 months TX,United States (fake)
+
+melman ( 17 years 1 CA,United
+
+401) month Original acct
+
+Below is another Melman I found years ago and hasn't been changed or re-created.
+
+In order to change their Ebay accounts this quickly, they need to have a contact who works at the new Ebay Office in Boston. They would ensure one of their friends gets a job there and these will be the folks assisting them with changing their accounts, because without those connections it's really hard to do.
+
+xmelman ( La) 14 years 5 months NJ,United States
+
+Below is from the Melman Club Package found on their website which they deleted as I can no longer find it. I did copy and paste this from their website years ago. There were nothing but sexual innuendos on the site and included with the restaurant/clubs menu, and the comments were a lot more graphic than what I'm submitting today. It discussed these private sexual offerings in the luxury basement of the club.
+
+One important item I forgot to include. The dubs website had a"NO CHILDREN Allowed" policy on the front page of the site, but yet they offered a "Kids Menu" !
+
+I definitely had this and am pretty sure someone deleted it from my docs. I probably have it printed, but my important documents are in my safety deposit boxes because the troopers kept having criminals break in my home to steal my evidence.
+
+I took the "kids menu" on this website to mean young girls. Below is what their menu actually said;
+
+#### "Catering Menu
+
+1. If you're into the group thing".
+
+### 2."Drink Menu
+
+If you want an umbrella in your drink, put it on the floor and stick yours in it."
+
+#### 3. "Dinner Menu
+
+Whether you're in the market for a nice piece of bass or a juicy burger, we've got your fix".
+
+Below are a couple of reviews posted by cops on the Neiman' brothers clubs and restaurants website. Does this or the below sound like a restaurant to you?
+
+Their Ebay will follow if I have it but the cops deleted my information via hacking me.
+
+#### From pk
+
+"After losing count of how many drinks I had, it was time to "break the seal". Guess what? Even the bathroom in this place was gorgeous. Individual stalls with solid wood doors and amazing lighting! With towel in hand I was in bathroom heaven."
+
+#### From Titanium
+
+"The Melman boyz are obviously doing something right because it's been over a year since Hub 51 opened their doors- and they are still absolutely packed!"
+
+(Titanium has canceled his account and I'm sure all of them have. This is why they block my letters because it buys them time to hide and delete evidence).
+
+titanium ( 114)
+
+#### From Tim K. O'shay..
+
+17 years 2 months NY,United States
+
+"The 'chos, or "nachos", upgraded from pulled chicken to crab, were [high pitched] awesome. The beef jerky was f\*\* amazing. And I know my jerky. Hell, I do it every night"
+
+The below buyer wrote this feedback after buying a 'book' from the Ebay account ' hub51'
+
+"Thanks, everything worked very well and quickly. Great German Model. Happy again."
+
+On my original email, I provided one of their accounts so you could see their "3 weeks to test the product",or women, comments and feedback- (this is to ensure their escorts are disease free)
+
+One of their feedback comments from the accounts '88girls' and 8o8girls has "\*S\*P\*A\*S\*S\* "III" as a description of his purchase . This stands for SP- ASS.
+
+The 88 girls accounts have been changed, altered, or deleted, as has the Mathiaspass account, but as you can see below it did exist because I also copied and pasted this from
+
+Ebay a few years ago. I'm not sure what the reason is, but when they write 88 it's a reference to prostitution. I placed one Ghislaine account above, but they also have one with an 88 next to it. Ghislaine was Jeff Epstein's accomplice.
+
+unity 9 Feedback forum 9 Feedback profile
+
+## profile
+
+ghislaine88 (1) Not a registered user 0
+
+Positive Feedback (last 12 months): 0% 0
+
+Member since: Feb-17-04 in Mexico
+
+As I said about, Trooper Manning keeps spreading rumors I was or am a pro, so right after I had surgery on my neck during 2012, he had one witch nurse say to me (for no reason) "How old are you, 88"? That was his way of harassing me and having others spread his messages. I've since had close to ten others he sent say the same to me and two people admitted they had been told to say it. The 88 is tied to sex services. I did report that nurse.
+
+Clearly they had many accounts which discussed dispatching women, how attractive the model was, how nice her touch was, and they had much worse which I did not supply. Over the years they have canceled or altered these accounts to avoid detection.
+
+This is why they block my emails, faxes, and complaints, because it gives them time to delete evidence and the MA AG troopers assist them. Mathias has been involved with them and this business for over twenty years. He's one they are also protecting.
+
+mathiaspass ( 2 12 years 10 German ) months y
+
+Trust me, the troopers and ICane's are not selling sheets and pillows as shown below! A few of their item descriptions are below and found on their erotic women and 'club' accounts. These were taken off the Melman, MathiasParis, and Hub51 Ebay escort accounts.
+
+"Nice cover, it 's a standard not a queen. I should have asked the measurements."
+
+"Love the pillows!!! Everything was described to a T! "
+
+"Great sheets at a great price. A professional in every way."
+
+"A REAL BEAUTY TO MY EYES...IM SHOCKED AN PLEASED THOROUGHLY!!TY! A"
+
+"great bedding'
+
+" These pillows are GREAT!!"
+
+""Goods were picked up personally! Contact Cute !!! Gladly again !!!"
+
+"Thank you! Absolutely the exact fufillment of my want!"
+
+(#4343936292)
+
+BABY GIRL LOVES HER NEW SHEETS - EVERYTHING (he most likely got a very young one)
+
+"Cute eBayers, Cash !!! !!! highly recommended, gladly again :-))"
+
+"worth the money i paid for. thanks"
+
+"GREAT PILLOW !!! EXCELLENT QUALITY - EXREMELY "
+
+"Beautiful and very classy. Thank you."
+
+"t00% virgin material, so far no error occurred and fast shipping very friendly"
+
+""Hammer fast delivery, Top Ware, super Ebayer.so makes Ebay fun, happy again"
+
+"Darling figurine. Thanks for offering it." "pretty doll"
+
+A separate erotic business found on the Melman Brothers site was a place named Mon Ami and the account is below. These are the accounts to check their bank statements and transactions. Monami had really graphic and obvious sex for money services. Like I said, they shut down these sites, comments, and photos right after I find them, but they can be found by their Ebay accounts. The accounts have emails and bank accounts tied to them and this is why I submit them.
+
+If it were legitimate police work there would be no rush to shut them down.
+
+They're online with the rapist Messina boys, O'Connells, Mathias', and predators such as Manning, and many other predators who need to be taken off the street. MA troopers always use Germany.
+
+monami.b ( io years 9 German 53) months
+
+monami\* ( 482) i6 years o months Germany
+
+One of their Ebay accounts is below and tied into the online escort websites.
+
+Ebay account named sellherfanny' -account has been shut down.
+
+Redaction is another .
+
+redaction (5?) 19 years o months Germany
+
+fox\_lady
+
+fox\_lady ( 2027) 15 years 7 months Germany
+
+Finally, below are a couple of police officers from this corrupt group explaining exactly how and why he would run his own escort business and I've also provided his Ebay account. This person is most likely dose to Mathias, thus his defending the `johns' caught and his obvious resentment towards women. This could be why they protect Mathias during their illegal stings, yet degrade, film, and exploit the women.
+
+This is a trooper and I believe the account will be owned by the same trooper whos in all of the above accounts with Mathias. This is taken from the cops sex webcam site about filming women. I will start with his Ebay account. Leonard had a lot to say about the subject and he could be one who runs them.
+
+leonardia ( as) 14 years 8 months Germany
+
+As you read Leonards words below, notice in the beginning he wrote "The" . This is not a typo and its written that way because it has meaning to the others.
+
+I've showed you their coded way of writing when I submitted Manning laughing about vandalising my vehicle again. A comma placed in such a way usually means comm-a, for Commonwealth of MA , or State. The people taking the "cut" he writes about is most likely the nightclub or STATE running it. In their case, the ICanes.
+
+The FBI gets the coded way of writing, ask Peter Strzok!
+
+Their enterprise is online based and many things are written in a coded way by those who do business with them understand, or someone like me who has monitored them online for over fifteen years. They do this to try and hide what they are doing within the enterprise.
+
+It's no different than the terrorists while conspiring online using coded writing such as "Providence" in place of writing Pakistan. (FBI Segmented on news)
+
+You'll also notice he intentionally misspelled trafficking. He left out the FK for a reason, because it means something or they are his initials. It could also represent Kane.
+
+Leonard 13 said this misspellings are intentional)
+
+T"he house still takes a cut...the bouncers take a cut...and its the same penis with a condom going into a mouth and a vagina. The only difference is in Tijuana you can't talk much unless you speak Spanish...and in Detroit its more rushed and cramped. Same services...a whore is a whore regardless of language.
+
+And finally...while I believe prostitution should be legal and regulated...all crimes have victims. There aren't "okay crimes" and "not okay crimes". Or at least there shouldn't be. Either prostitution is a crime or it isn't. Either we arrest both parties and punish accordingly, or we don't. My whole point was that its a joke...because it is so prevalent...yet people act all "scared" they might get busted. Police don't care about hookers or strippers or johns or even pimps. They pretend to care about sex traficing...and they care about sex with kids...but like the previous poster mentioned...cops are paying for sex too...
+
+Of matter of fact...I talked to an escort once...asked her what the worst experience was ever with the profession. She told me it was when a cop showed up, called up 2 buddies, then proceeded to repeatedly rape and beat her..then steal her money. Cops generally believe they are above the law."
+
+(Below he writes about legalizing prostitution and how he would make it safer. Note his testing the girls for diseases. I read one of his replies to a bad Ebay feedback he received on their 'girls dispatched' and he wrote "It takes 3 weeks to take care of the testing before dispatching them". I feel he's both trying to promote and justify what they are running, and explaining why and how as LE they're running an escort business.)
+
+"z) escalate the clientel. Current clients are lawbreakers and sex addicts and morally challenged...only. legalizing brings in more mainstream clients that may still be "morally questionable"...but not as dangerous. Like strip dubs...you still get the creeps....but you also get the college kids and bachelor parties and old lonely guys.
+
+2) Allow women the ability to easily report problems. Now a woman has to admit being a prostitute to report a crime. Legalizing it means she's just a woman with a job and can report problems.
+
+(providing you don't report their group!)
+
+3) protects men...making sure the women are disease free...allowing men to come forward when they are robbed or assaulted.
+
+4) it allows law enforcement to focus on areas of real crime...kidnappings, sex slavery, violence, rapes, child exploitation.
+
+legalizing doesn't kills the roaches, but it turns the lights on and makes them scatter."
+
+#### Leonardia said
+
+Iowa
+
+APRIL 19, 2013
+
+"I don't have a problem with it. I have a problem with paying for just the "idea" of it. And I have a problem that if I were to be busted...the gal would get a "talkin to" and id be in jail and a sex offender/sex trafficer."
+
+"And I'm fine with that arrangement...just don't be harder on the "Johns" than you are on the hookers. The hookers get a slap on the wrist and a warning. The Johns get their cars impounded, are fined \$300-\$500, and end up on a sex offender registry...and still have to go before a judge and probably lose their wife and kids and job/livlihood. Meanwhile the cops know that hooker by name and see her posting her ads every single night like clockwork. Its silly."
+
+"But walking out semi buzzed, out \$400 and knowing that I just blew my load in a tight 19 year old who if I met at a regular bar wouldn't give me the lime of day...at least "sorts" worth it."
+
+"But then...you start to touch...they don't mind...and you get the nerve to ask for more. And if you got the cash...even if that particular dancer won't play for pay...she'll point you to the dancers in the place that will. Its just common sense. If a guy asks you to strip to your panties and he'll give ya \$20...and you're okay with that...the next logical question is "what would ya do for \$50?"
+
+I agree with most folks here...legalize it, regulate it...let's stop pretending already! But where I get annoyed is the unfair treatment of "johns" versus the treatment of escorts/dancers/prostitutes as "victims". Victims!? Damn...where's the sympathy for us fellas that just dropped \$400 at the club and got nothin to show for it other than a used condom and a need to make sure we have a blood test done to rule out any "potential issues".
+
+Gawker wrote; "My favorite club has cops in and out all the time.. I know one dancer who provides extras to an off duty officer. It's not in anyone's best interest to stir up trouble. Why the government doesn't make consensual sex legal and tax it escapes me. So much of the sex trade is part of the underground cash economy that it never shows up on the federal or state books. Instead, many women make big bucks working on their backs, get welfare, health care, earned income tax credits, etc. many escorts do take credit cards as do most clubs, but the real money is cash."
+
+Gawkers Ebay
+
+gaincer ( 89) a years 5 months Germany
+
+They'll lie and tell you they are running illegal stings with the private investigators to stop prostitution, yet judging by their above comments and websites, they clearly pay for them, support them, and I believe run them. But, they have the high up law enforcement who will tip them off if anyone is about to raid them because I'm sure they're getting a little on the side as well.
+
+I can go on and on with this as I have many of their erotic women sites, but I've already sent it in to their friends at MSP, DOJ, and the AG who chose to ignore it. Now a little girl is dead and I'm sure plenty more women are being victimized by this group because no one cared enough to look into it.
+
+Perhaps one day MA will care, when they assault and degrade a female in their family, be it a daughter, sister, mother, or young grandchild. This is a group of misogynistic men and police who prey on women and their track record proves it.
+
+It's funny, a law abiding and honest trooper wrote the truth about arresting a judges daughter who propositioned him with sex for leniency, and the Massachusetts State Police were up in arms over that truth! The former Colonel immediately dragged the trooper out of bed to discipline him for writing the truth and commanding him to remove and alter the arrest report!
+
+So it's apparently okay for the common citizens, kids, or women to be degraded, physically raped, and abused, but they dare not touch or verbally speak truthfully about a cop, children of judges or law enforcement, and politicians!
+
+Trooper Manning told everyone I know I was a prostitute and I never propositioned anyone, nor was I ever charged with a crime as the judge's daughter was.
+
+Until law enforcement and their connections to the judiciary is cleaned up there will never be true or real justice, it's nothing but a sham criminal justice system where everyone is concerned about their own pockets and political future.
+
+I know I've supplied an awful lot today, but I've sent it one document at a time over the years. I wanted you to see the ties between the rapist O'Connell and their erotic connections to him, the troopers, and the nightclub owners.
+
+You don't have to read it all but it's there in case you need more information. Someone has to enforce the rule of law and reform law enforcement on ALL levels in order to straighten out the problems and injustices going on in New England.
+
+Law enforcement, lawyers, and judges are not above the law, but they are being treated as such, while the common citizens and poor are ruled with an iron fist.
+
+The Denise Robert document is below and is about an unsolved murder the FBI is investigating. I feel I may have been the intended target and it's explained here. There
+
+are many motives as to why they want me silenced but no motives found for killing her. We walked the same nightly route.
+
+https://docs.google.com/document/d/idTTJ3P52IluCvIZ5deo8ODOYrNvKsmUshkfJtD x8oDM/edit?usp=sharing
+
+My sexual assault document is below and gives more background information on each player above. It also shows you some of the violent and disgusting public writings of one Ma State Trooper (Manning) who is the one sending criminals my way to threaten, harass, and commit crimes against me. You can read his own words on this document and after doing so you may believe all of the above. He along with Kane are ones being protected by the union, lawyers, and politicians they work with on the side.
+
+https://docs.google.com/document/d/ikBGywweNHwgkn ulfxb4-TQBrG4oRdXX-6 og6zzGwQ/edit?usp=sharing
+
+I am fairly certain it's some of the wealthy business owners mentioned on my sexual assault document who are funding these troopers to chase me around and try to silence me. Trooper Manning has been hacking me and malting it hard for me to prepare this document and he will do all he can to ensure it's not received. He is doing his best to protect O'Connell, Messina's, and the BNEG Group the Kanes.
+
+I refer to them as a criminal enterprise because that's how they refer to themselves as shown on the below two documents titled 'Enterprise 1 and 2'. It also touches a little on their voting and campaign shells they've tried to hide.
+
+#### Enterprises
+
+https://docs.google.com/document/d/1C2 orcCBWD7onyEmm9eC9WUXZJNkmiuhr XQwFug41VQ/edit?usp=sharing
+
+### Enterprise2
+
+https://docs.google.com/document/dRICHKsrWThq6yTwnYylm2-rI-EoYFYAsxAREIP hSKH s/edit?usp=sharing
+
+BNEG Nightclub Group/Kanes- This document is brand new and just sent to the DOJ in Boston. It was sent to Fred Wyshak and Zach Hafer. This is a small amount of what I've sent over the years but will give a little background on the club owners in case you are interested.
+
+https://docs.google.com/document/dRBTxxxmiZ24IVp1O2 R6BZMQMfY51LMqMzXC cacltnI/edit?usp=sharing
+
+BNEG- Liquor and Taxes - This document is also new and goes with the above doc. It offers suggestions of other illegal activities they could be engaging in. Tax free liquor for their many clubs and restaurants and tax evasion.
+
+https://docs.google.com/document/d/ivoin3pHCxWuvVmKShK qWOJNDwGGHOQ wtw9RqrViLTE/edit?usp=sharing
+
+### The PDF version of this document
+
+file:///home/chronos/u-e6bfef9c95cdaoc25a8o78a445b8o5fgbc8bbf2e/Downloads/BI LL%20O%E2%80%99CONNELLandChildVictim%20(2).pdf
+
+Morrissey-Aliases. One corrupt attorney and her many aliases. She works very closely with the wealthy construction co owners, (Messina and O'Connell), politicians, DOT, and works with the police on the side which she tries to hide.
+
+https://docs.google.com/document/d/nOxx-t31wkGMuL458oYH9hiPnIoAu\_XMycqVaZ 4P5Cclio/edit?usp=sharing
+
+This document was created mainly with hopes of investigating the little girls death and to stop this group from harming more children and women, but I added a bit extra in order to show you the mentality, cover ups, and criminality taldng place within this enterprise and to question why this little girls death wasn't properly investigated
+
+Why do they feel I'm more important to surveil for years as opposed to the cocaine trafficker and child rapist O'Connell, and why do LE and the politicians refuse to look his way? (money)
+
+Why have they attempted SO many set-up and entrapment tactics against me if I were really committing all of these crimes?
+
+Why the unlawful charges against me ? Because they want me put away in order to silence me. All unlawful charges were dismissed or I was found not guilty and they failed at all of their set-up and entrapment tactics. All have been explained to MA authorities who want to protect them.
+
+O'Connell and his family have been getting away with grave crimes for years and he will not stop abusing little girls knowing he is protected in Mass. Someone needs to stop him before he hurts another, and if you pass this document back to Massachusetts his protection circle will take over again and nothing will happen.
+
+Is the rule of law only for the poor? MA is a sham democracy operating as a lawless law enforcement agency. Their actions, or lack thereof, make it impossible for the good law enforcement officers to do their jobs properly and make it impossible for victims to get justice.
+
+How can the good police make arrests of protected major drug dealers or wealthy rapists when they know their political friends will get them off and they'll be targeted for doing their jobs? They abuse the honest police as well, especially if they tell the truth and refuse to comply with the unethical activities.
+
+Lisa Kenney
+
+![](_page_51_Picture_7.jpeg)

marker2/ds9/EFTA00083270/EFTA00083270.metadata.json

@@ -0,0 +1,2191 @@
+{
+  "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083270.pdf",
+  "engine": {
+    "marker_major": "2",
+    "marker_version": "2.0.0",
+    "mode": "balanced",
+    "use_llm": false,
+    "force_ocr": false,
+    "disable_ocr": false,
+    "output_format": "markdown",
+    "preserve_source": false
+  },
+  "fingerprint": "d889ea60d5548ac4",
+  "pages": 52,
+  "chars": 85281,
+  "elapsed_seconds": 21.6,
+  "image_assets": [
+    "_page_2_Picture_2.jpeg",
+    "_page_16_Figure_17.jpeg",
+    "_page_18_Picture_0.jpeg",
+    "_page_24_Picture_3.jpeg",
+    "_page_32_Picture_2.jpeg",
+    "_page_33_Picture_3.jpeg",
+    "_page_51_Picture_7.jpeg"
+  ],
+  "marker_metadata": {
+    "table_of_contents": [
+      {
+        "title": "BILL O'CONNELL Both Protecting and Protected by the CORRUPT",
+        "heading_level": null,
+        "page_id": 8,
+        "polygon": [
+          [
+            100.36800000000001,
+            156.32999999999998
+          ],
+          [
+            515.2304077148438,
+            156.32999999999998
+          ],
+          [
+            515.2304077148438,
+            173.36248779296875
+          ],
+          [
+            100.36800000000001,
+            173.36248779296875
+          ]
+        ]
+      },
+      {
+        "title": "SOUTH SHORE SEX and DRUG KINGPIN",
+        "heading_level": null,
+        "page_id": 8,
+        "polygon": [
+          [
+            175.03199999999998,
+            189.54000000000002
+          ],
+          [
+            411.78375244140625,
+            189.54000000000002
+          ],
+          [
+            411.78375244140625,
+            206.73248291015625
+          ],
+          [
+            175.03199999999998,
+            206.73248291015625
+          ]
+        ]
+      },
+      {
+        "title": "rofile",
+        "heading_level": null,
+        "page_id": 12,
+        "polygon": [
+          [
+            69.156,
+            97.75543212890625
+          ],
+          [
+            117.78932189941406,
+            97.75543212890625
+          ],
+          [
+            117.78932189941406,
+            117.8505859375
+          ],
+          [
+            69.156,
+            117.8505859375
+          ]
+        ]
+      },
+      {
+        "title": "BHTCC -grants",
+        "heading_level": null,
+        "page_id": 14,
+        "polygon": [
+          [
+            67.932,
+            399.3299999999999
+          ],
+          [
+            157.25485229492188,
+            399.3299999999999
+          ],
+          [
+            157.25485229492188,
+            415.93353271484375
+          ],
+          [
+            67.932,
+            415.93353271484375
+          ]
+        ]
+      },
+      {
+        "title": "SAMHSA -Funded Grants",
+        "heading_level": null,
+        "page_id": 14,
+        "polygon": [
+          [
+            67.932,
+            477.9
+          ],
+          [
+            213.07131958007812,
+            477.9
+          ],
+          [
+            213.07131958007812,
+            494.68353271484375
+          ],
+          [
+            67.932,
+            494.68353271484375
+          ]
+        ]
+      },
+      {
+        "title": "Facts on the O'Connell Family",
+        "heading_level": null,
+        "page_id": 19,
+        "polygon": [
+          [
+            197.06400000000002,
+            427.68
+          ],
+          [
+            388.1433410644531,
+            427.68
+          ],
+          [
+            388.1433410644531,
+            444.86248779296875
+          ],
+          [
+            197.06400000000002,
+            444.86248779296875
+          ]
+        ]
+      },
+      {
+        "title": ")ack profile",
+        "heading_level": null,
+        "page_id": 28,
+        "polygon": [
+          [
+            68.544,
+            236.32293701171875
+          ],
+          [
+            228.47833251953125,
+            236.32293701171875
+          ],
+          [
+            228.47833251953125,
+            271.03057861328125
+          ],
+          [
+            68.544,
+            271.03057861328125
+          ]
+        ]
+      },
+      {
+        "title": "ARTICLE WI",
+        "heading_level": null,
+        "page_id": 29,
+        "polygon": [
+          [
+            284.58,
+            223.56000000000003
+          ],
+          [
+            333.65673828125,
+            223.56000000000003
+          ],
+          [
+            333.65673828125,
+            233.80572509765625
+          ],
+          [
+            284.58,
+            233.80572509765625
+          ]
+        ]
+      },
+      {
+        "title": "ARTICLE VIII",
+        "heading_level": null,
+        "page_id": 29,
+        "polygon": [
+          [
+            284.58,
+            268.11
+          ],
+          [
+            335.0209045410156,
+            268.11
+          ],
+          [
+            335.0209045410156,
+            278.64
+          ],
+          [
+            284.58,
+            278.64
+          ]
+        ]
+      },
+      {
+        "title": "CERTIFICATE OF CORRECTION (GENERAL LAWS, CHAPTER 156B, SECTION 6A)",
+        "heading_level": null,
+        "page_id": 30,
+        "polygon": [
+          [
+            214.2,
+            111.78000000000002
+          ],
+          [
+            380.052,
+            111.78000000000002
+          ],
+          [
+            380.052,
+            130.41
+          ],
+          [
+            214.2,
+            130.41
+          ]
+        ]
+      },
+      {
+        "title": "Facts and ties to escort services and sex workers.",
+        "heading_level": null,
+        "page_id": 31,
+        "polygon": [
+          [
+            68.544,
+            416.34000000000003
+          ],
+          [
+            377.05181884765625,
+            416.34000000000003
+          ],
+          [
+            377.05181884765625,
+            433.23248291015625
+          ],
+          [
+            68.544,
+            433.23248291015625
+          ]
+        ]
+      },
+      {
+        "title": "\"Catering Menu",
+        "heading_level": null,
+        "page_id": 39,
+        "polygon": [
+          [
+            67.932,
+            290.78999999999996
+          ],
+          [
+            174.08013916015625,
+            290.78999999999996
+          ],
+          [
+            174.08013916015625,
+            308.36248779296875
+          ],
+          [
+            67.932,
+            308.36248779296875
+          ]
+        ]
+      },
+      {
+        "title": "2.\"Drink Menu",
+        "heading_level": null,
+        "page_id": 39,
+        "polygon": [
+          [
+            67.932,
+            362.88
+          ],
+          [
+            165.83013916015625,
+            362.88
+          ],
+          [
+            165.83013916015625,
+            380.73248291015625
+          ],
+          [
+            67.932,
+            380.73248291015625
+          ]
+        ]
+      },
+      {
+        "title": "3. \"Dinner Menu",
+        "heading_level": null,
+        "page_id": 39,
+        "polygon": [
+          [
+            67.932,
+            435.7800000000001
+          ],
+          [
+            176.33013916015625,
+            435.7800000000001
+          ],
+          [
+            176.33013916015625,
+            452.73248291015625
+          ],
+          [
+            67.932,
+            452.73248291015625
+          ]
+        ]
+      },
+      {
+        "title": "From pk",
+        "heading_level": null,
+        "page_id": 39,
+        "polygon": [
+          [
+            67.932,
+            622.08
+          ],
+          [
+            128.9153289794922,
+            622.08
+          ],
+          [
+            128.9153289794922,
+            638.3625030517578
+          ],
+          [
+            67.932,
+            638.3625030517578
+          ]
+        ]
+      },
+      {
+        "title": "From Titanium",
+        "heading_level": null,
+        "page_id": 40,
+        "polygon": [
+          [
+            68.544,
+            94.77000000000001
+          ],
+          [
+            170.29495239257812,
+            94.77000000000001
+          ],
+          [
+            170.29495239257812,
+            110.36248779296875
+          ],
+          [
+            68.544,
+            110.36248779296875
+          ]
+        ]
+      },
+      {
+        "title": "From Tim K. O'shay..",
+        "heading_level": null,
+        "page_id": 40,
+        "polygon": [
+          [
+            68.544,
+            340.2
+          ],
+          [
+            206.59535217285156,
+            340.2
+          ],
+          [
+            206.59535217285156,
+            356.36248779296875
+          ],
+          [
+            68.544,
+            356.36248779296875
+          ]
+        ]
+      },
+      {
+        "title": "profile",
+        "heading_level": null,
+        "page_id": 41,
+        "polygon": [
+          [
+            72.216,
+            212.22000000000003
+          ],
+          [
+            132.80516052246094,
+            212.22000000000003
+          ],
+          [
+            132.80516052246094,
+            231.73406982421875
+          ],
+          [
+            72.216,
+            231.73406982421875
+          ]
+        ]
+      },
+      {
+        "title": "Leonardia said",
+        "heading_level": null,
+        "page_id": 46,
+        "polygon": [
+          [
+            68.544,
+            339.39
+          ],
+          [
+            161.70005798339844,
+            339.39
+          ],
+          [
+            161.70005798339844,
+            355.3535461425781
+          ],
+          [
+            68.544,
+            355.3535461425781
+          ]
+        ]
+      },
+      {
+        "title": "Enterprises",
+        "heading_level": null,
+        "page_id": 49,
+        "polygon": [
+          [
+            67.932,
+            547.5600000000001
+          ],
+          [
+            148.31044006347656,
+            547.5600000000001
+          ],
+          [
+            148.31044006347656,
+            565.2324981689453
+          ],
+          [
+            67.932,
+            565.2324981689453
+          ]
+        ]
+      },
+      {
+        "title": "Enterprise2",
+        "heading_level": null,
+        "page_id": 49,
+        "polygon": [
+          [
+            67.932,
+            662.5799999999999
+          ],
+          [
+            149.49044799804688,
+            662.5799999999999
+          ],
+          [
+            149.49044799804688,
+            680.3625030517578
+          ],
+          [
+            67.932,
+            680.3625030517578
+          ]
+        ]
+      },
+      {
+        "title": "The PDF version of this document",
+        "heading_level": null,
+        "page_id": 50,
+        "polygon": [
+          [
+            68.544,
+            382.32
+          ],
+          [
+            284.8264465332031,
+            382.32
+          ],
+          [
+            284.8264465332031,
+            400.23248291015625
+          ],
+          [
+            68.544,
+            400.23248291015625
+          ]
+        ]
+      }
+    ],
+    "page_stats": [
+      {
+        "page_id": 0,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            22
+          ],
+          [
+            "Line",
+            10
+          ],
+          [
+            "Text",
+            3
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 1,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            383
+          ],
+          [
+            "Line",
+            33
+          ],
+          [
+            "Text",
+            10
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 2,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            59
+          ],
+          [
+            "Line",
+            29
+          ],
+          [
+            "Text",
+            13
+          ],
+          [
+            "Picture",
+            1
+          ],
+          [
+            "Caption",
+            1
+          ],
+          [
+            "PageFooter",
+            1
+          ],
+          [
+            "PictureGroup",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 3,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            55
+          ],
+          [
+            "Line",
+            28
+          ],
+          [
+            "Text",
+            4
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 4,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            47
+          ],
+          [
+            "Line",
+            24
+          ],
+          [
+            "Text",
+            6
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 5,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            50
+          ],
+          [
+            "Line",
+            24
+          ],
+          [
+            "Text",
+            6
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 6,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            43
+          ],
+          [
+            "Line",
+            22
+          ],
+          [
+            "Text",
+            7
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 7,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            51
+          ],
+          [
+            "Line",
+            26
+          ],
+          [
+            "Text",
+            5
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 8,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            59
+          ],
+          [
+            "Line",
+            30
+          ],
+          [
+            "Text",
+            7
+          ],
+          [
+            "SectionHeader",
+            2
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 9,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            59
+          ],
+          [
+            "Line",
+            30
+          ],
+          [
+            "Text",
+            9
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 10,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            65
+          ],
+          [
+            "Line",
+            33
+          ],
+          [
+            "Text",
+            7
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 11,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            47
+          ],
+          [
+            "Line",
+            24
+          ],
+          [
+            "Text",
+            8
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 12,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            51
+          ],
+          [
+            "Line",
+            26
+          ],
+          [
+            "Text",
+            10
+          ],
+          [
+            "SectionHeader",
+            1
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 13,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            58
+          ],
+          [
+            "Line",
+            28
+          ],
+          [
+            "Text",
+            11
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 14,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            45
+          ],
+          [
+            "Line",
+            22
+          ],
+          [
+            "Text",
+            15
+          ],
+          [
+            "SectionHeader",
+            2
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 15,
+        "text_extraction_method": "surya",
+        "block_counts": [
+          [
+            "Text",
+            4
+          ],
+          [
+            "Form",
+            2
+          ],
+          [
+            "PageFooter",
+            2
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 16,
+        "text_extraction_method": "surya",
+        "block_counts": [
+          [
+            "Text",
+            16
+          ],
+          [
+            "PageHeader",
+            6
+          ],
+          [
+            "PageFooter",
+            2
+          ],
+          [
+            "SectionHeader",
+            1
+          ],
+          [
+            "Figure",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 17,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            31
+          ],
+          [
+            "Line",
+            16
+          ],
+          [
+            "Text",
+            5
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 18,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            43
+          ],
+          [
+            "Line",
+            22
+          ],
+          [
+            "Text",
+            7
+          ],
+          [
+            "Picture",
+            1
+          ],
+          [
+            "Caption",
+            1
+          ],
+          [
+            "PageFooter",
+            1
+          ],
+          [
+            "PictureGroup",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 19,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            69
+          ],
+          [
+            "Line",
+            34
+          ],
+          [
+            "Text",
+            8
+          ],
+          [
+            "SectionHeader",
+            1
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 20,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            54
+          ],
+          [
+            "Line",
+            27
+          ],
+          [
+            "Text",
+            12
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 21,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            57
+          ],
+          [
+            "Line",
+            29
+          ],
+          [
+            "Text",
+            10
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 22,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            57
+          ],
+          [
+            "Line",
+            28
+          ],
+          [
+            "Text",
+            10
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 23,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            41
+          ],
+          [
+            "Line",
+            19
+          ],
+          [
+            "Text",
+            10
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 24,
+        "text_extraction_method": "surya",
+        "block_counts": [
+          [
+            "Text",
+            2
+          ],
+          [
+            "PageFooter",
+            2
+          ],
+          [
+            "Figure",
+            1
+          ],
+          [
+            "Picture",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 25,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            57
+          ],
+          [
+            "Line",
+            29
+          ],
+          [
+            "Text",
+            9
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 26,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            59
+          ],
+          [
+            "Text",
+            25
+          ],
+          [
+            "Line",
+            24
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 27,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            61
+          ],
+          [
+            "Line",
+            31
+          ],
+          [
+            "Text",
+            9
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 28,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            45
+          ],
+          [
+            "Line",
+            22
+          ],
+          [
+            "Text",
+            7
+          ],
+          [
+            "PageHeader",
+            3
+          ],
+          [
+            "SectionHeader",
+            1
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 29,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            83
+          ],
+          [
+            "Line",
+            33
+          ],
+          [
+            "Text",
+            13
+          ],
+          [
+            "SectionHeader",
+            2
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 30,
+        "text_extraction_method": "surya",
+        "block_counts": [
+          [
+            "Text",
+            27
+          ],
+          [
+            "SectionHeader",
+            2
+          ],
+          [
+            "PageFooter",
+            2
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 31,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            63
+          ],
+          [
+            "Line",
+            31
+          ],
+          [
+            "Text",
+            8
+          ],
+          [
+            "SectionHeader",
+            1
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 32,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            47
+          ],
+          [
+            "Line",
+            24
+          ],
+          [
+            "Text",
+            8
+          ],
+          [
+            "Picture",
+            1
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 33,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            64
+          ],
+          [
+            "Line",
+            31
+          ],
+          [
+            "Text",
+            5
+          ],
+          [
+            "Picture",
+            1
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 34,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            59
+          ],
+          [
+            "Line",
+            30
+          ],
+          [
+            "Text",
+            10
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 35,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            67
+          ],
+          [
+            "Line",
+            33
+          ],
+          [
+            "Text",
+            8
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 36,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            39
+          ],
+          [
+            "Line",
+            16
+          ],
+          [
+            "Text",
+            9
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 37,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            51
+          ],
+          [
+            "Line",
+            25
+          ],
+          [
+            "Text",
+            11
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 38,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            53
+          ],
+          [
+            "Line",
+            23
+          ],
+          [
+            "Text",
+            21
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 39,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            47
+          ],
+          [
+            "Line",
+            24
+          ],
+          [
+            "Text",
+            10
+          ],
+          [
+            "SectionHeader",
+            4
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 40,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            51
+          ],
+          [
+            "Line",
+            22
+          ],
+          [
+            "Text",
+            11
+          ],
+          [
+            "SectionHeader",
+            2
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 41,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            52
+          ],
+          [
+            "Line",
+            23
+          ],
+          [
+            "Text",
+            9
+          ],
+          [
+            "SectionHeader",
+            1
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 42,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            61
+          ],
+          [
+            "Line",
+            30
+          ],
+          [
+            "Text",
+            19
+          ],
+          [
+            "PageHeader",
+            3
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 43,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            43
+          ],
+          [
+            "Line",
+            19
+          ],
+          [
+            "Text",
+            11
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 44,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            51
+          ],
+          [
+            "Line",
+            24
+          ],
+          [
+            "Text",
+            12
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 45,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            54
+          ],
+          [
+            "Line",
+            27
+          ],
+          [
+            "Text",
+            5
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 46,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            51
+          ],
+          [
+            "Line",
+            26
+          ],
+          [
+            "Text",
+            10
+          ],
+          [
+            "SectionHeader",
+            1
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 47,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            52
+          ],
+          [
+            "Line",
+            26
+          ],
+          [
+            "Text",
+            6
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 48,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            61
+          ],
+          [
+            "Line",
+            31
+          ],
+          [
+            "Text",
+            10
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 49,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            51
+          ],
+          [
+            "Line",
+            25
+          ],
+          [
+            "Text",
+            7
+          ],
+          [
+            "SectionHeader",
+            2
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 50,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            51
+          ],
+          [
+            "Line",
+            26
+          ],
+          [
+            "Text",
+            9
+          ],
+          [
+            "SectionHeader",
+            1
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 51,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            45
+          ],
+          [
+            "Line",
+            23
+          ],
+          [
+            "Text",
+            7
+          ],
+          [
+            "Picture",
+            1
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      }
+    ],
+    "debug_data_path": "debug_data/EFTA00083270"
+  }
+}

marker2/ds9/EFTA00083322/EFTA00083322.md

@@ -0,0 +1,9 @@
+![]()![]()**Subject:** Hi everyone.docx
+
+**Date:** Wed, 08 Jul 2020 16:46:49 +0000
+
+**Attachments:** Hi\_everyone.docx
+
+---
+
+![]()

marker2/ds9/EFTA00083322/EFTA00083322.metadata.json

@@ -0,0 +1,54 @@
+{
+  "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083322.pdf",
+  "engine": {
+    "marker_major": "2",
+    "marker_version": "2.0.0",
+    "mode": "balanced",
+    "use_llm": false,
+    "force_ocr": false,
+    "disable_ocr": false,
+    "output_format": "markdown",
+    "preserve_source": false
+  },
+  "fingerprint": "d889ea60d5548ac4",
+  "pages": 1,
+  "chars": 130,
+  "elapsed_seconds": 1.34,
+  "image_assets": [],
+  "marker_metadata": {
+    "table_of_contents": [],
+    "page_stats": [
+      {
+        "page_id": 0,
+        "text_extraction_method": "surya",
+        "block_counts": [
+          [
+            "Span",
+            14
+          ],
+          [
+            "Text",
+            13
+          ],
+          [
+            "Line",
+            7
+          ],
+          [
+            "PageFooter",
+            2
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      }
+    ],
+    "debug_data_path": "debug_data/EFTA00083322"
+  }
+}

marker2/ds9/EFTA00083323/EFTA00083323.md

@@ -0,0 +1,19 @@
+Hi everyone.
+
+Last week had some very notable achievements:
+
+a \$678 million civil settlement with Novartis for years of paying illicit kickbacks; and also the arrest of GELANE Maxwell, a co-conspirator of Jeffrey Epstein.
+
+I cheer both of those the teams that worked so hard to bring those worthy cases.
+
+Of course, some of our most important achievements happen out of the spotlight, and I want to celebrate everyone who has:
+
+- taken on new gun cases to combat our District's recent rise in violence;
+- chipped in to skillfully handle the increase in FOIA litigation; and
+- diligently prepared thoughtful responses to compassionate release motions.
+
+And many thanks to all of our AUSAs, paralegals, and staff who are shouldering the work of the Office every day.
+
+We miss seeing you, but even when you are out of sight, we know we are lucky to have you.
+
+Stay safe and keep up the great work.

marker2/ds9/EFTA00083323/EFTA00083323.metadata.json

@@ -0,0 +1,62 @@
+{
+  "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083323.pdf",
+  "engine": {
+    "marker_major": "2",
+    "marker_version": "2.0.0",
+    "mode": "balanced",
+    "use_llm": false,
+    "force_ocr": false,
+    "disable_ocr": false,
+    "output_format": "markdown",
+    "preserve_source": false
+  },
+  "fingerprint": "d889ea60d5548ac4",
+  "pages": 1,
+  "chars": 895,
+  "elapsed_seconds": 0.52,
+  "image_assets": [],
+  "marker_metadata": {
+    "table_of_contents": [],
+    "page_stats": [
+      {
+        "page_id": 0,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            41
+          ],
+          [
+            "Line",
+            21
+          ],
+          [
+            "Text",
+            8
+          ],
+          [
+            "ListItem",
+            3
+          ],
+          [
+            "ListGroup",
+            1
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      }
+    ],
+    "debug_data_path": "debug_data/EFTA00083323"
+  }
+}

marker2/ds9/EFTA00083324/EFTA00083324.md

@@ -0,0 +1,261 @@
+### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x
+
+20 Cr. 330 (AJN)
+
+### MEMORANDUM OF GHISLAINE MAXWELL IN OPPOSITION TO THE GOVERNMENT'S MOTION FOR DETENTION
+
+Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600
+
+Jeffrey S. Pagliuca (pro hac vice admission pending) Laura A. Menninger HADDON, MORGAN & FORMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: 303-831-7364
+
+Attorneys for Ghislaine Maxwell
+
+## TABLE OF CONTENTS
+
+|                                                                           | Page                                                          |
+|---------------------------------------------------------------------------|---------------------------------------------------------------|
+| PRELIMINARY STATEMENT                                                     | 1                                                             |
+| ARGUMENT                                                                  | 5                                                             |
+| I. The Conditions Created by the COVID-19 Pandemic Mandate the Release of |                                                               |
+| Ms. Maxwell.                                                              | 5                                                             |
+| II. The Government Has Not Carried Its Burden Under 18 U.S.C. § 3142.     | 9                                                             |
+| A. Applicable Law                                                         | 9                                                             |
+| B. Ms. Maxwell Has Rebutted the Presumption That She Poses a Flight       |                                                               |
+| Presence In Court                                                         | 11                                                            |
+| 1. Ms. Maxwell's Personal History and Characteristics                     |                                                               |
+| Demonstrate That She Is Not a Flight Risk                                 | 12                                                            |
+| 2.                                                                        | The Nature and Circumstances of the Charges and the Weight of |
+| the Evidence Militate in Favor of Bail                                    | 17                                                            |
+| 3.                                                                        | The Proposed Bail Package Is More Than Adequate to Secure     |
+| Ms. Maxwell's Presence                                                    | 20                                                            |
+| CONCLUSION                                                                | 22                                                            |
+
+#### TABLE OF AUTHORITIES
+
+|                                                                                                                       | <b>Page(s)</b> |
+|-----------------------------------------------------------------------------------------------------------------------|----------------|
+| <b>Cases</b>                                                                                                          |                |
+| <i>Hung v. United States</i> ,<br>439 U.S. 1326 (1978).....                                                           | 16             |
+| <i>United States v. Abdellatif El Mokadem</i> ,<br>No. 19-CR-646 (AJN), 2020 WL 3440515 (S.D.N.Y. June 23, 2020)..... | 17             |
+| <i>United States v. Alindato-Perez</i> ,<br>627 F. Supp. 2d 58 (D.P.R. 2009).....                                     | 18             |
+| <i>United States v. Bodmer</i> ,<br>No. 03-cr-947(SAS), 2004 WL 169790 (S.D.N.Y. Jan. 28. 2004).....                  | 16             |
+| <i>United States v. Boustani</i> ,<br>932 F.3d 79 (2d Cir. 2019).....                                                 | 20             |
+| <i>United States v. Carrillo-Villa</i> ,<br>20-MJ-3073 (SLC).....                                                     | 8              |
+| <i>United States v. Chandler</i> , 19-CR-867 (PAC),<br>2020 WL 1528120 (S.D.N.Y. Mar. 31, 2020).....                  | 8, 9           |
+| <i>United States v. Conway</i> ,<br>No. 4-11-70756 MAG(DMR), 2011 WL 3421321 (N.D. Cal. Aug. 3, 2011) .....           | 10, 18         |
+| <i>United States v. Crowell</i> ,<br>No. 06-CR-291E(F), 2006 WL 3541736 (W.D.N.Y. Dec. 7, 2006) .....                 | 11             |
+| <i>United States v. Deutsch</i> ,<br>No. 18-CR-502 (FB), 2020 WL 3577398 (E.D.N.Y. July 1, 2020) .....                | 11, 18         |
+| <i>United States v. DiGiacomo</i> ,<br>746 F. Supp. 1176 (D. Mass. 1990) .....                                        | 14             |
+| <i>United States v. Dominguez</i> ,<br>783 F.2d 702 (7th Cir. 1986) .....                                             | 10             |
+| <i>United States v. Dreier</i> ,<br>596 F. Supp. 2d 831 (S.D.N.Y. 2009).....                                          | 21             |
+| <i>United States v. English</i> ,<br>629 F.3d 311 (2d Cir. 2011).....                                                 | 10, 11         |
+
+| United States v. Epstein,                                                                           |               |
+|-----------------------------------------------------------------------------------------------------|---------------|
+| 425 F. Supp. 3d 306 (S.D.N.Y. 2019) United States v. Esposito,                                      | 17            |
+| 309 F. Supp. 3d 24 (S.D.N.Y. 2018) United States v. Friedman,                                       | 21            |
+| 837 F.2d 48 (2d Cir. 1988) United States v. Hansen,                                                 | 13, 18        |
+| 108 F. App'x 331 (6th Cir. 2004) United States v. Hanson,                                           | 16            |
+| 613 F. Supp. 2d 85 (D.D.C. 2009) United States v. Karni,                                            | 16            |
+| 298 F. Supp. 2d 129 (D.D.C. 2004) United States v. Kashoggi,                                        | 16            |
+| 717 F. Supp. 1048 (S.D.N.Y. 1989) United States v. Mattis,                                          | 16            |
+| No. 20-1713, 2020 WL 3536277 (2d Cir. June 30, 2020) United States v. Moscaritolo,                  | 10            |
+| No. 10 Cr. 4 (JL), 2010 WL 309679 (D.N.H. Jan. 26, 2010) United States v. Sabhnani,                 | 18            |
+| 493 F.3d 63 (2d Cir. 2007) United States v. Salerno,                                                | 9, 10, 16, 18 |
+| 481 U.S. 739 (1987) United States v. Stephens, 15-CR-95 (MN),                                       | 9             |
+| 2020 WL 1295155 (S.D.N.Y. Mar. 19, 2020) United States v. Peres,                                    | 5, 6, 7, 8    |
+| No. 3:20-CR-18-J-32JBT, 2020 WL 1042051 (M.D. Fla. Mar. 4, 2020) United States v. Williants-Bethea, | 18            |
+| No. 18-CR-78 (MN), 2020 WL 2848098 (S.D.N.Y. June 2, 2020) Statutes                                 | 6             |
+| 18 U.S.C. § 3142                                                                                    | passim        |
+
+#### PRELIMINARY STATEMENT
+
+Ghislaine Maxwell respectfully submits this Memorandum in Opposition to the government's July 2, 2020 Memorandum in Support of Detention ("Gov. Mem.").
+
+It is difficult to recall a recent case that has garnered more public attention than the government's prosecution of Jeffrey Epstein ("Epstein"). In July 2019, Epstein was indicted for offenses relating to sexual misconduct, amid overwhelming media attention focused on the nature of the charges and Epstein's wealth and lifestyle. On August 10, 2019, Epstein died in federal custody, and the media focus quickly shifted to our client—wrongly trying to substitute her for Epstein—even though she'd had no contact with Epstein for more than a decade, had never been charged with a crime or been found liable in any civil litigation, and has always denied any allegations of claimed misconduct. Many of these stories and online posts were threatening and harassing to our client and those close to her.
+
+But sometimes the simplest point is the most critical one: Ghislaine Maxwell is not Jeffrey Epstein. She was not named in the government's indictment of Epstein in 2019, despite the fact that the government has been investigating this case for years. Instead, the current indictment is based on allegations of conduct that allegedly occurred roughly twenty-five years ago. Ms. Maxwell vigorously denies the charges, intends to fight them, and is entitled to the presumption of innocence. Far from "hiding," she has lived in the United States since 1991, has litigated civil cases arising from her supposed ties to Epstein, and has not left the country even once since Epstein's arrest a year ago, even though she was aware of the pending, and highly publicized, criminal investigation. She should be treated like any other defendant who comes before this Court, including as to bail. Under the Bail Reform Act, case law in this Circuit and other circuits, as well as decisions of this Court, Ms. Maxwell should be released on bail, subject to the strict conditions proposed below.
+
+Background. Ms. Maxwell, 58, is a naturalized U.S. citizen who has resided in the United States since 1991. She is also a citizen of France, where she was born, and of the United Kingdom, where she was educated and spent her childhood and formative years. Ms. Maxwell graduated from Oxford University. She moved to the United States in 1991, and has lived in this country ever since that time. Ms. Maxwell has maintained extremely close relationships with her six siblings and her nephews and nieces. They all stood by her in the aftermath of the July 2019 indictment of Epstein and continue to stand by her now. She is especially close to two of her sisters and their children, all of whom reside in the United States. Ms. Maxwell also has numerous friends in the United States who themselves have children, and she is a godmother to many of them. Ms. Maxwell's family and friends have remained committed to her because they do not believe the allegations against her, which do not match the person they have known for decades.
+
+The Government's Position. The government has the burden of persuasion in showing that detention is warranted, and that there are no conditions or combination of conditions that will secure a defendant's appearance in court. In seeking to carry this burden, the government relies on the presumption of detention in 18 U.S.C. § 3142(e)(3)(E), and argues that Ms. Maxwell poses a flight risk because she supposedly lacks ties to the United States; is a citizen of the United Kingdom and France, as well as a citizen of the United States, and has passports for each country; has traveled internationally in the past; and has financial means. And echoing recent media stories, the government speculates that Ms. Maxwell was "hiding" from law enforcement during the pendency of the investigation, even though she has been in regular contact with the government, through counsel, since Epstein's arrest. Finally, the government argues that the nature and circumstances of the offense and the weight of the evidence warrant
+
+detention. Importantly, in contrast with the bail position it took with Epstein, the government does not and cannot assert that Ms. Maxwell presents a danger to the community under Section 3142(g)(4).
+
+Ms. Maxwell's Response. The Court should exercise its discretion to grant bail to Ms. Maxwell, on the strict conditions proposed below (or as modified by the Court), for two compelling reasons.
+
+First, the COVID-19 crisis and its impact on detained defendants warrants release. As this Court has noted, the COVID-19 pandemic represents an unprecedented health risk to incarcerated individuals, and COVID-19-related restrictions on attorney communications with pretrial detainees significantly impair a defendant's ability to prepare her defense. Simply put, under these circumstances, if Ms. Maxwell continues to be detained, her health will be at serious risk and she will not be able to receive a fair trial. (See infra Section I, pages 5 to 9).
+
+Second, the Court should grant bail because the government has not met its burden under the Bail Reform Act and controlling case law. The presumption relied on by the government may be rebutted, and is so here. Ms. Maxwell has strong ties to the community: she is a U.S. citizen and has lived in this country for almost 30 years; she ran a non-profit company based in the United States until the recent media frenzy about this case forced her to wind it down to protect her professional colleagues and their organizations; and she has very close ties with family members and friends in New York and the rest of the country. Nor does her conduct indicate that she is a flight risk: she has no prior criminal record; has spent years contesting civil litigation arising from her supposed ties to Epstein; and has remained in the United States from the time of Epstein's arrest until the present, with her counsel in regular contact with the government. She did not flee, but rather left the public eye, for the entirely understandable
+
+purpose of protecting herself and those close to her from the crush of media and online attention and its very real harms—those close to her have suffered the loss of jobs, work opportunities, and reputational damage simply for knowing her. The government's remaining arguments about Ms. Maxwell's passports, citizenship, travel and financial means— also fail because they would require that every defendant with multiple citizenship and financial means be denied bail, which is simply not the law. Finally, as discussed below, the government's position regarding the nature and circumstances of the offense and weight of its evidence, which relates to alleged conduct that is roughly twenty-five years old, is not persuasive and does not alter the bail analysis. (See infra Section II, pages 9 to 21).
+
+Proposed Bail Conditions. In light of the above, we propose the following bail conditions, which are consistent with those that courts in this Circuit have imposed in analogous situations: (i) a \$5 million personal recognizance bond, co-signed by six financially responsible people, all of whom have strong ties to Ms. Maxwell, and secured by real property in the United Kingdom worth over \$3.75 million; (ii) travel restricted to the Southern and Eastern Districts of New York; (iii) surrender of all travel documents with no new applications; (iv) strict supervision by Pretrial Services; (v) home confinement at a residence in the Southern District of New York with electronic GPS monitoring; (vi) visitors limited to Ms. Maxwell's immediate family, close friends and counsel; (vii) travel limited to Court appearances and to counsel's office, except upon application to Pretrial Services and the government; and (viii) such other terms as the Court may deem appropriate under Section 3142.
+
+The Bail Reform Act does not discard the presumption of innocence; Ms. Maxwell is entitled to that presumption here, as she is in all aspects of this case. See 18 U.S.C. § 31420) ("Nothing in this section [3142] shall be construed as modifying or limiting the presumption of
+
+innocence."). The government has failed to meet its burden of establishing that Ms. Maxwell presents an "actual risk of flight" and must be detained under Section 3142. The strict bail conditions outlined above are appropriate under the circumstances and are the "least restrictive" set of conditions that will "reasonably assure" Ms. Maxwell's appearance in Court, without the health and access to counsel risks inherent in the government's request that Ms. Maxwell be detained pending trial. See 18 U.S.C. § 3142 (c)(1)(B). Under the controlling legal standards, Ms. Maxwell should be released on bail.
+
+# ARGUMENT
+
+There are two compelling reasons why the Court should order Ms. Maxwell's release on bail pursuant to the strict conditions she has proposed:
+
+First, Ms. Maxwell will be at significant risk of contracting COVID-19 if she is detained, and she will not be able to meaningfully participate in the preparation of her defense due to the restrictions that have been placed on attorney visits and phone calls in light of the pandemic.
+
+Second, the government has failed to carry its burden under 18 U.S.C. § 3142 that no combination of conditions can be imposed that will reasonably assure Ms. Maxwell's presence in court.
+
+## I. The Conditions Created by the COVID-19 Pandemic Mandate the Release of Ms. Maxwell.
+
+Impact of COVID-I9 on the Prison Population. We submit that the conditions created by the COVID-19 pandemic compel Ms. Maxwell's release pursuant to appropriate bail conditions. Four months ago, this Court held in United States v. Stephens, 15-CR-95 (AJN), 2020 WL 1295155 (S.D.N.Y. Mar. 19, 2020), that COVID-19 is an "unprecedented and extraordinarily dangerous" threat that justifies release on bail. Id. at \*2. In that case, the defendant, who had no underlying medical conditions, filed an emergency motion for reconsideration of the Court's
+
+prior detention order based in part on the risks brought on by COVID-19. At the time, COVID-19 had only begun to take its devastating toll on New York, and there was no known outbreak in the prison population. Nevertheless, the Court noted that "inmates may be at a heightened risk of contracting COVID-19 should an outbreak develop," and, based in part on this changed circumstance, ordered the defendant released. Id.
+
+Since the Court issued its opinion in Stephens, the COVID-19 risks to inmates have increased dramatically, as there have been significant outbreaks of COVID-19 in correctional facilities. In the last month alone, the number of prison inmates known to have COVID-19 has doubled to 68,000, and prison deaths tied to COVID-19 have increased by 73 percent.' Indeed, as of July 2, 2020, nine of the ten largest known clusters of the coronavirus in the United States are in federal prisons and county jails.2 As this Court noted last month, "the `inability [of] individuals to socially distance, shared communal spaces, and limited access to hygiene products' [in correctional facilities] make community spread all but unavoidable." United States v. Williams-Bethea, No. 18-CR-78 (AJN), 2020 WL 2848098, at \*5 (S.D.N.Y. June 2, 2020) (citation and internal quotation marks omitted). The risks are further enhanced by the possibility of a second wave of coronavirus cases.;
+
+In particular, COVID-19 has begun to spread through the Metropolitan Detention Center (MDC), where Ms. Maxwell has been housed since the Bureau of Prisons (BOP) transferred her there on July 6, 2020. According to the MDC's statistics, as of April 3, 2020, two inmates and
+
+I Timothy Williams, et al., Coronavirus Cases Rise Sharply in Prisons Even as They Plateau Nationwide, N.Y. Times, available at https://www.nytimes.com/2020/06/16/uskoronavirus-inmates-prisons-jails.html (last updated June 30, 2020).
+
+<sup>2</sup> Coronavirus in the U.S: Latest Map and Case Count, N.Y. Times, available at https://www.nytimes.com/interactive./2020/us/coronavirus-us-cases.htmlliclusters(last updated July 2, 2020).
+
+<sup>3</sup>See, e.g., Audrey Cher, WHO's Chief Scientist Says There's a "Very Real Risk" of a Second Wave of Coronavirus As Economies Reopen, CNBC, June 9, 2020, available at httns://www.cnbc.com/2020/06/10Avho-says-theres-realrisk-of-second-coronavirus-wave-as-economies-reopen.html.
+
+five staff had tested positive; by June 30, 2020, those numbers had risen to 14 and 41, respectively.4 The increased spread among prisons means that the COVID-19 risks that were present in the Stephens case four months ago are far more serious for Ms. Maxwell now and mandate her release.
+
+Impact of COVID-19 on the Ability to Prepare the Defense. The Stephens opinion provides yet another independent basis that, we submit, requires Ms. Maxwell's release: if she is detained, her ability to meet with her attorneys and prepare for her defense will be significantly impaired and she will not be able to meaningfully participate in the preparation of her defense.
+
+In Stephens, the Court found that this factor required the defendant's release under 18 U.S.C. § 3142(i), which provides for temporary release based on a determination that such release is "necessary for preparation of the person's defense." Stephens, 2020 WL 1295155 at \*3. The Court noted that the spread of COVID-19 had compelled the BOP to suspend all inperson visits, including legal visits, except as allowed on a case-by-case basis. Id. at \*3. That suspension persists to this day.5 In a case such as this, which will require assessing evidence relating to events that occurred approximately twenty-five years ago, including documents and personal recollections, numerous in-person meetings between counsel and Ms. Maxwell will be critical to the preparation of the defense. The recent resurgence of the pandemic calls into question whether these meetings will ever be able to happen in advance of her trial. As in
+
+See April 3, 2020 Report from the BOP regarding the Metropolitan Detention Center and Metropolitan Correctional Center ("MDC and MCC Report"), available at https://img.nyed.uscourts.gov/files/reports/bop/20200403 BOP Report.pdf and June 30, 2020 MDC and MCC Report, available at https://www.nyed.uscourts.gov/pubibop/MDC MCC 20200630 071147.pdf.
+
+<sup>\$</sup> See BOP COVID-19 Modified Operations Plan, available at https://www.bop.govicoronavirus/covid19 status.jsp.
+
+Stephens, Ms. Maxwell's inability to meet with her attorneys while this policy is in effect constitutes a "compelling reason" requiring her release. Stephens, 2020 WL 1295155 at \*3.6
+
+Even speaking by phone with Ms. Maxwell presents daunting challenges due to COVID-19-related protocols requiring at least 72 hours' notice to schedule a call, unless it is urgent, in which case counsel can email a request to the MDC. As counsel learned this past week, however, even an urgent call request does not mean the call will take place in the time required. At approximately 5:30 p.m. on July 6, 2020, the Court ordered us to confer with Ms. Maxwell about waiving her physical presence at the arraignment, initial appearance, and bail hearing, and ordered counsel for both sides to jointly report back by 9:00 p.m. that night with a proposed date and time for these proceedings. We promptly emailed the MDC to request an urgent call, making specific reference to the Court's Order, but were not connected with Ms. Maxwell until 9:00 p.m. There will no doubt be other orders of the Court with no guarantees we will be able to reach our client in time if she is detained.' In addition, during this past week, Ms. Maxwell has not been able to physically review documents and has had limited access to writing materials.
+
+The prohibition on in-person visits means we must read to her any documents requiring her review, and she has virtually no ability to take notes. The age of the allegations in this case compound these problems. Under the current circumstances, Ms. Maxwell cannot review
+
+<sup>6</sup>Since the Court issued its opinion in Stephens, numerous other courts in this District have ordered defendants released on bail, over the government's objection, due to the pandemic and its impact on the defendant's ability to prepare for trial. See, e.g., United States v. Carrillo-Villa, 20-MJ-3073 (SLC) (S.D.N.Y. Apr. 6, 2020) (releasing undocumented defendant in drug conspiracy case because of inability to meaningfully communicate with lawyer and risk of COVID-19); United States v. Hudson, 19-CR-496 (CM) (S.D.N.Y. Mar. 19, 2020) (releasing defendant in drug conspiracy, loansharking, and extortion case, whose two prior, pre-COVID-I9 bail applications were denied, because of inability to prepare for upcoming trial and risk of COVID-I9); United States v. Chandler, 19-CR-867 (PAC), 2020 WL 1528120, at \*1 (S.D.N.Y. Mar. 31, 2020) (releasing defendant on felon in possession case, with prior manslaughter conviction, due to inability to prepare for trial due to COVID-19 restrictions).
+
+<sup>7</sup>The government has recently worked with the BOP to set up a standing call between counsel and Ms. Maxwell each morning until the initial appearance to facilitate attorney-client communications. While we greatly appreciate these efforts, they are a short-term patch to a persistent problem that shows no signs of abating. Nor would it be appropriate, on an ongoing basis, for the prosecutors to be involved in and dictate the date and time of our communications with our client in connection with the preparation of our defense.
+
+documents and other evidence from approximately twenty-five years ago and meaningfully assist in the preparation of her defense. These restrictions are additional "compelling reasons" justifying her release. See id.8
+
+# II. The Government Has Not Carried Its Burden Under 18 U.S.C. § 3142.
+
+The grave concerns raised by the current COVID-19 crisis notwithstanding, Ms. Maxwell must be released because she has met her limited burden of production showing that she does not pose a flight risk, and the government has entirely failed to demonstrate that no release condition or combination of conditions exist that will reasonably assure Ms. Maxwell's presence in court.
+
+# A. Applicable Law
+
+As the Supreme Court has recognized, "[i]n our society liberty is the norm, and detention prior to trial or without trial is the carefully limited exception." United States v. Salerno, 481 U.S. 739, 755 (1987). Pretrial detention is appropriate only where "no condition or combination of conditions will reasonably assure the appearance of the [defendant]." United States v. Sabhnani, 493 F.3d 63, 75 (2d Cir. 2007) (quoting 18 U.S.C. § 3142(e)). The Bail Reform Act provides that a court "shall order the pretrial release" of the defendant (18 U.S.C. § 3142(b)) (emphasis added), but may impose bail conditions if "such release will not reasonably assure the appearance" of the defendant in court. 18 U.S.C. § 3142(c). Where conditions are necessary, such release shall be "subject to the least restrictive . . . set of conditions that [the court] determines will reasonably assure the appearance of the person as required." 18 U.S.C. § 3142(c)(1)(B) (emphasis added). Consequently, "[u]nder this statutory scheme, `it is only a limited group of offenders who should be denied bail pending trial."' Sabhnani, 493 F.3d at 75 (citation and internal quotation marks omitted).
+
+<sup>8</sup>See also Letter of Sean Hecker to Hon. Margo K. Brodie (July 8, 2020), Federal Defenders of New York, Inc. v. Federal Bureau of Prisons, et at, No. 19 Civ. 660 (E.D.N.Y.) (Doc. No. 78) (detailing absence of in-person visitation, highly limited VTC and telephone call capacity, and issues pertaining to legal mail and legal documents).
+
+The government bears a dual burden in seeking pre-trial detention. First, the government must show "by a preponderance of the evidence that the defendant ... presents an actual risk of flight." Sabhnani, 493 F.3d at 75 (emphasis added). If the government is able to satisfy this burden, it must then "demonstrate by a preponderance of the evidence that no condition or combination of conditions could be imposed on the defendant that would reasonably assure his presence in court." Id.
+
+In determining whether there are conditions of release that will reasonably assure the appearance of the defendant, the court must consider (1) the nature and circumstances of the offense charged; (2) the weight of the evidence against the person; (3) the history and characteristics of the person; and (4) the nature and seriousness of the danger to any person or the community that would be posed by the person's release. 18 U.S.C. § 3142(g).
+
+In this case, unlike in the Epstein case, the government does not contend that Ms. Maxwell poses any danger to the community, and therefore the fourth factor does not apply.
+
+The Bail Reform Act contains a rebuttable presumption, applicable based on certain of the crimes charged here, that no conditions will reasonably assure against flight. See 18 U.S.C. § 3 I42(e)(3)(E). In cases where this presumption applies, the "defendant bears a limited burden of production—not a burden of persuasion—to rebut that presumption by coming forward with evidence that [she] does not pose ... a risk of flight." See United States v. English, 629 F.3d 311, 319 (2d Cir. 2011) (quotation omitted). This rebuttable presumption can be readily satisfied, United States v. Conway, No. 4-11-70756 MAG (DMR), 2011 WL 3421321, at \*2 (N.D. Cal. Aug. 3, 2011), and "[a]ny evidence favorable to a defendant that comes within a category listed in § 3142(g) can affect the operation" of the presumption. United States v. Dominguez, 783 F.2d 702, 707 (7th Cir. 1986); see also United States v. Mattis, No. 20-1713,
+
+2020 WL 3536277, at \*4-5 (2d Cir. June 30, 2020). Although the presumption "remains a factor to be considered" even after the defendant has met her burden of production, "[a]t all times ... the government retains the ultimate burden of persuasion by ... a preponderance of the evidence" that the defendant poses a flight risk that cannot be addressed by any bail conditions. English, 629 F.3d at 319 (citation and internal quotation marks omitted); see also United States v. Deutsch, No. I 8-CR-502 (FB), 2020 WL 3577398, at \*5 (E.D.N.Y. July I, 2020). And regardless of the presence of the presumption or the nature of the charges alleged, "[n]othing in this section [3142] shall be construed as modifying or limiting the presumption of innocence." 18 U.S.C. § 3142(j); see also United States v. Crowell, No. 06-CR-291E(F), 2006 WL 3541736, at \*3 (W.D.N.Y. Dec. 7, 2006) (those charged with crimes involving minors "continue to enjoy the presumption of innocence in setting conditions of release.").
+
+### B. Ms. Maxwell Has Rebutted the Presumption That She Poses a Flight Risk, and the Government Has Not Carried Its Burden That No Combination of Conditions Can Be Imposed To Reasonably Assure Her Presence In Court
+
+The government has not carried its burden of establishing that no set of conditions will reasonably assure Ms. Maxwell's appearance in court. As set forth below, Ms. Maxwell's personal history, her family and other ties to this country, and her conduct prior to her arrest easily rebut the presumption that she presents a risk of flight. For these same reasons, the government cannot establish that the strict bail conditions she proposes, which are consistent with a number of cases in this Circuit in which courts have ordered release, will not "reasonably assure" her presence in court. Accordingly, the Court should order Ms. Maxwell released pursuant to her proposed conditions.
+
+### 1. Ms. Maxwell's Personal History and Characteristics Demonstrate That She Is Not a Flight Risk
+
+- a. Ms. Maxwell Has No Prior Criminal Record, and Has Significant Ties to the United States and the New York Region
+
+Ms. Maxwell's history and characteristics do not "strongly support detention," as the government contends (Gov. Mem. at 6), but instead demonstrate that she is firmly rooted in this country and that her appearance can be reasonably assured with appropriate bail conditions. Ms. Maxwell has no criminal record, which includes the approximately twentyfive-year period from the time the conduct alleged in the indictment took place to the present. Ms. Maxwell also has significant ties to the United States. She has lived in this country for almost 30 years and became a naturalized U.S. citizen in 2002. Ms. Maxwell also has strong family ties to this country. Two of her sisters, who have agreed to co-sign her bond, live in the United States, and they have several children who are U.S.-born citizens. Ms. Maxwell is very close with her sisters and maintains regular contact with them, as well as with her nieces and nephews. Ms. Maxwell also has numerous close friends and professional colleagues who reside in this country. In sum, the United States has been Ms. Maxwell's home for decades.
+
+- b. Ms. Maxwell Has Actively Litigated Civil Cases in this District and Has Not Left the United States Since Epstein's 2019 Arrest
+
+Ms. Maxwell has never once attempted to "hide" from the government or her accusers, and has never shown any intent to leave the country. To the contrary, Ms. Maxwell has always vehemently denied that she was involved in illegal or improper conduct related to Epstein, and her conduct has been entirely consistent with someone who fully intends to remain in this country and fight any allegations brought against her. For example, since 2015, and continuing through today, Ms. Maxwell has actively litigated several civil
+
+cases related to Epstein in the Southern District of New York and has sat for depositions in those cases. Similarly, throughout the course of the criminal investigation of this case, which has been publicly reported on for nearly a year, Ms. Maxwell has remained in the United States. Indeed, on July 7, 2019, the day after Epstein's arrest, Ms. Maxwell reached out to the prosecutors in the Southern District of New York, through counsel, and maintained regular contact with them right up to the point of her arrest.
+
+The government's broad assertion that Ms. Maxwell has engaged in "frequent international travel" in the last three years (Gov. Mem. at 6) obscures the critical point: she has not left the country even once since Epstein's arrest. Ms. Maxwell's decision to remain in the United States after Epstein's arrest and subsequent death in August 2019 is particularly significant because any incentive she may have had to flee would have been even more acute at that time. Within days of Epstein's death, a steady stream of press articles began turning the public's attention to Ms. Maxwell—wrongly substituting her for Epstein—and speculating that she had become the prime target of the government's investigation.9 Adding even more fuel to this fire, several of the women claiming to be victims of Epstein's abuse began publicly calling for her immediate arrest and prosecution. Despite the increasing risk of being criminally charged, and the media firestorm that was redirected toward her after Epstein's death, and despite having ample opportunity to leave the country, Ms. Maxwell stayed in the United States for almost an entire year until she was arrested. These actions weigh heavily in favor of release. See United States v. Friedman,
+
+<sup>9</sup> See, e.g., Spotlight turns on Jeffrey Epstein's British socialite :fixer' Ghislaine Maxwell after his suicide — but will she be prosecuted?, Daily Mail (Aug. 10, 2019) https:/Avww.dailymail.co.uk/news/arlicle-7344765/Spotlight-turns-Jeffrey-Epsteins-fixer-Ghislaine-Maxwell-suicide.html• Ghislaine Maxwell• the woman accused of helping Jeffrey Epstein groom girls, The Guardian (Aug. 12, 2019), htlps://www.theguardian.com/us-news/2019/aug/12/ghislainemaxwell-woman-accusethjeffrepepstein-groom-girls•British socialite Ghislaine Maxwell in spotlight after Epstein's apparent suicide, NBC News (Aug. 12, 2019) https://vnvw.nbcnews.corninews/us-news/british-socialiteghislaine-maxwell-spotlight-after-epstein-s-apparent-suicide-n 1041111.
+
+837 F.2d 48, 49-50 (2d Cir. 1988) (overturning district court's decision that defendant posed a flight risk based in part on the ground that the defendant took "no steps" to flee jurisdiction in three-week period between execution of search warrant at home and arrest); United States v. DiGiacomo, 746 F. Supp. 1176, 1179-80 (D. Mass. 1990) (concluding defendants did not present a flight risk because each of them "for three years knew there was substantial evidence of the likely charges against them and did not attempt to flee before indictment").
+
+Indeed, the absence of any allegation by the government that Ms. Maxwell was taking steps to leave the country at the time of her arrest is conspicuous. The government has offered no proof that she was making plans to leave the country. In fact, had the government alerted her counsel that she was about to be arrested, we would have arranged for Ms. Maxwell's prompt, voluntary surrender. Instead, the government arrested Ms. Maxwell without warning on the day before the July 4th holiday, thus ensuring that she would be in federal custody on the one-year anniversary of Epstein's arrest.
+
+- c. Ms. Maxwell's Actions to Protect Herself From Intrusive Media Coverage and Death Threats Do Not Demonstrate an Intent to Flee
+
+Furthermore, the steps Ms. Maxwell took to leave the public eye after Epstein's arrest are not indicative of a risk of flight. The government notes that Ms. Maxwell dropped out of public view after Epstein's arrest, which the government seeks to portray as "hiding" from the law. The government further argues that she has taken several steps to avoid detection, including moving residences and switching her phone and email address. (Gov. Mem. at 8). But Ms. Maxwell did not take these steps to hide from law enforcement or evade prosecution. Instead, they were necessary measures that Ms. Maxwell was forced to
+
+take to protect herself, her family members, her friends and colleagues, and their children, from unrelenting and intrusive media coverage, threats, and irreparable reputational harm.
+
+Ever since Epstein's arrest, Ms. Maxwell has been at the center of a crushing onslaught of press articles, television specials, and social media posts painting her in the most damning light possible and prejudging her guilt. The sheer volume of media reporting mentioning Ms. Maxwell is staggering. Since Epstein's arrest, she has been mentioned in literally thousands of media publications, news reports, and other online content. The media attention also spawned a carnival-like atmosphere of speculation about her whereabouts. In November 2019, the British tabloid, The Sun, even offered a £10,000 bounty for information about Ms. Maxwell's location. A headline reminiscent of a Wild West wanted poster read: "WANTED: The Sun is offering a £10,000 reward for information on Jeffrey Epstein pal Ghislaine Maxwell."10 And in the days leading up to her arrest, there was a deluge of media reports (all untrue) claiming that Ms. Maxwell was hiding out in an apartment in Paris to avoid questioning by the FBI." She has seen helicopters flying over her home and reporters hiding in the bushes. Indeed, since Ms. Maxwell's arrest on July 2, 2020, her counsel has been flooded with hundreds of media inquiries and solicitations from members of the public.
+
+The "open season" declared on Ms. Maxwell after Epstein's death has come with an even darker cost — she has been the target of alarming physical threats, even death threats, and has had to hire security guards to ensure her safety. The media feeding frenzy, which has only intensified in recent months, has also deeply affected her family and friends. Some of Ms. Maxwell's closest friends who had nothing whatsoever to do with Epstein have lost their jobs or
+
+I°See https://uww.the-sun.cominews/740 I 8/the-sun-is-offering-a-10000-reveard-for-informatiomon-jeffrey-epsteinpal-ghislaine-maxwellt
+
+See, e.g., https://www.dailymail.co.ukinews/ article-8444137/Jeffrey-Epsteins-fugitive-madam-Ghislaine-Maxwell-hiding-luxury-Paris.html.
+
+suffered severe professional and reputational damage simply by being associated with her. Ms. Maxwell therefore did what any responsible person would do — she separated herself from everyone she cares about and removed herself from the public eye in order to keep herself and her friends out of harm's way.12
+
+Lacking any evidence required under the governing standard that Ms. Maxwell presents an "actual risk of flight," Sabhnani, 493 F.3d at 75, the government's flight risk argument is reduced to the following: Ms. Maxwell is a woman of means who has foreign citizenship and has traveled internationally in the past, and who now faces serious charges. But if that were sufficient, then virtually every defendant with a foreign passport and any meaningful amount of funds would need to be detained as a flight risk. See Hung v. United States 439 U.S. 1326, 1329 (1978) (to detain based on risk of flight, government must show more than "opportunities for flight," and instead must establish an "inclination on the part of [the defendant] to flee"). That is not what the Bail Reform Act requires. Indeed, courts in this Circuit and elsewhere commonly find that bail conditions can adequately address risk of flight, even where individuals have foreign citizenship and passports or otherwise substantial foreign connections, and financial means. See, e.g., Sabhnani, 493 F.3d at 66; United States v. Hansen, 108 F. App'x 331 (6th Cir. 2004); United States v. Hanson, 613 F. Supp. 2d 85 (D.D.C. 2009); United States v. Bodmer, No. 03-cr-947(SAS), 2004 WL 169790, at \*2-3 (S.D.N.Y. Jan. 28. 2004); United States v. Karni, 298 F. Supp. 2d 129 (D.D.C. 2004); United States v. Kashoggi, 717 F. Supp. 1048, 1050-52 (S.D.N.Y. 1989).
+
+Finally, the ongoing travel restrictions caused by the COVID-19 pandemic would pose a significant hurdle to Ms. Maxwell's ability to flee the United States, particularly to
+
+<sup>12</sup> The media spotlight has also drawn out people who claim to speak for Ms. Maxwell, and even purport to have had direct communications with her, but who, in fact, have no ties to Ms. Maxwell whatsoever. One such person has even given numerous television interviews on news shows in the United Kingdom.
+
+France and the United Kingdom.13 Notably, two weeks ago, this Court recognized in United States v. Abdellatif El Mokadem, No. 19-CR-646 (AN), 2020 WL 3440515 (S.D.N.Y. June 23, 2020) that "concerns regarding risk of flight are mitigated by the ongoing [COVID-19] pandemic, which has understandably curtailed travel across the country, and, indeed, around the world." Id. at \*1. In that case, despite finding detention to be warranted on two prior occasions, the Court concluded that the government could no longer establish flight risk and ordered the defendant released pending sentencing. Id. ("Taking account of the COVID-19 pandemic, which had not yet reached this country when the Court last considered Defendant's custody status, the balance now clearly and convincingly tips in Defendant's favor . . ."). Consideration of this factor weighs heavily in favor of release on the proposed bail conditions here.
+
+### 2. The Nature and Circumstances of the Charges and the Weight of the Evidence Militate in Favor of Bail
+
+The Defense Has Rebutted the Presumption Relating to Certain of the Charges. The government relies on the statutory presumption of detention applicable to offenses involving minor victims. (Gov. Mem. at 4-5.) But unlike the position it took with Epstein, the government does not contend that Ms. Maxwell poses any danger to the community, or that she suffers from compulsive or addictive sexual proclivities. See United States v. Epstein, 425 F. Supp. 3d 306, 314-15 (S.D.N.Y. 2019). Even according to the indictment, Ms. Maxwell's alleged participation in offenses involving minors ended in 1997. Here, the only
+
+<sup>13</sup> See, e,g., E.U. Formalizes Reopening, Barring Travelers From U.S., N.Y. Times, (June 30, 2020), available at https://www.nytimes.com/2020/06/30/world/europe/eu-reopening-blocics-us-travelers.html (confirming that the European Union will not open its borders to travelers from the United States, and "[t]ravelers' country of residence, not their nationality, will be the determining factor for their ability to travel to countries in the European Union"); England Drops Its Quarantine for Mast Visitors, but Not Those From the U.S., N.Y. Times (July 3, 2020), available at https://www.nytimes.com/2020/07/03/world/europeThritain-quarantine-us-coronavirus.html (confirming that England will leave mandatory 14-day quarantine restrictions in place for travelers coming from the United States).
+
+applicable presumption relates to risk of flight, and, as noted, Ms. Maxwell has rebutted that presumption based on her ties to the United States, her decision to remain in this country after Epstein's arrest, and all of the other reasons discussed above. This Court should follow other courts in this Circuit and elsewhere that have found that defendants rebutted the presumption and imposed appropriately strict bail conditions in cases involving alleged offenses against minors. See Deutsch, 2020 WL 3577398, at \*5-6; United States v. Veres, No. 3:20-CR-18-J-32JBT, 2020 WL 1042051, at \*3-4 (M.D. Fla. Mar. 4, 2020); Conway, 2011 WL 3421321, at \*4-5.
+
+The Impact of the Potential Penalties Is Overstated. The government asserts that detention is warranted because of the potential for a long sentence in this case. (Gov. Mem. at 4-5.) This oversimplifies the governing standard. Although the severity of potential punishment is a relevant consideration, the Second Circuit "require[s] more than evidence of the commission of a serious crime and the fact of a potentially long sentence to support a finding of risk of flight." Friedman, 837 F.2d at 49-50 (district court's finding that defendant posed a risk of flight was clearly erroneous, despite potential for "long sentence of incarceration"); see also Sabhnani, 493 F.3d at 65, 76-77 (reversing detention order where defendants agreed to significant physical and financial restrictions, despite the fact that they faced a "lengthy term of incarceration"). Accordingly, the asserted potential for a long sentence does not meet the government's burden of persuasion.14
+
+<sup>14</sup> The government relies on United States v. Alindato-Perez, 627 F. Supp. 2d 58, 66 (D.P.R. 2009), cited approvingly by United States v. Moscaritolo, No. 10 Cr. 4 (IL), 2010 WL 309679, at •2 (D.N.H. Jan. 26, 2010) for the proposition that "[t]he steeper the potential sentence, the more probable the flight risk is, especially considering the strong case of the government ...." (Gov. Mem. at 5.) But Alindato-Perez is easily distinguished on its facts from Ms. Maxwell's case. Alindato-Perez was a narcotics case that did not involve 20-year old conduct as here, but instead involved a conspiracy that "continu[ed] until the date of the indictment." 627 F. Supp. 2d at 60-61. The evidence included eleven "clearly incriminating video tapes" and testimony from various cooperating witnesses, and the defendant faced a 10-year mandatory minimum sentence. Id. at 61-64. These factors are not present in this case.
+
+Moreover, the government overstates the potential for Ms. Maxwell to spend "decades in prison" if she is convicted. (Gov. Mem. at 5.) In fact, her likely total exposure even if she were convicted on all counts is 10 years, assuming the Court were to follow the traditional practice in this District and impose concurrent sentences. Although a 10-year sentence would be significant, it is a far cry from the government's forecast, further demonstrating that the government has not met its burden of showing Ms. Maxwell is an actual risk of flight.
+
+The Government's Case Is Subject to Significant Challenges. In evaluating the strength of the government's case, we note that Ms. Maxwell intends to mount several legal challenges to the indictment, including that: (i) this prosecution is barred by Epstein's September 24, 2007 non-prosecution agreement with the Department of Justice, which covers "any potential co-conspirators of Epstein"; (ii) the conspiracy, enticement of minors, and transporting of minors charges are time-barred and otherwise legally flawed; and (iii) the two perjury charges are subject to dismissal on several legal grounds. as In addition, as we understand from the face of the indictment, the government's case is based primarily on the testimony of three individuals about events that allegedly occurred roughly 25 years ago between 1994 and 1997. It is inherently more difficult to prosecute cases relating to decades-old conduct. These issues further call into question the strength of the government's case, and provide an independent basis justifying release on bail.
+
+<sup>1</sup>S The defense is also considering whether the government's comments in connection with this case conform to Local Criminal Rule 23.1, and whether to seek appropriate relief from the Court.
+
+### 3. The Proposed Bail Package Is More Than Adequate to Secure Ms. Maxwell's Presence
+
+For the reasons stated above, the Court should release Ms. Maxwell because the circumstances created by the COVID-19 pandemic will greatly increase her personal risk and prevent her from meaningfully participating in her defense, and because the government has not carried its burden under 18 U.S.C. § 3142. We respectfully submit that the proposed bail package represents the "least restrictive" set of conditions that will reasonably ensure Ms. Maxwell's presence in court. 18 U.S.C. § 3142 (c)(1)(B).
+
+The package includes six co-signers-Ms. Maxwell's siblings, relatives and friends—many of whom reside in the United States, and all of whom continue to support her despite the unrelenting media attacks that Ms. Maxwell and they, themselves, have suffered as a result of this case. Each of them has voluntarily agreed to assume responsibility for an extremely large bond amount of \$5 million, in order to secure her appearance. The bond is also to be secured by real property in the United Kingdom worth roughly \$3.75 million. The package also includes stringent travel and physical restrictions, including surrendering all passports and no new travel applications, travel restricted to the Southern and Eastern Districts of New York, and home detention with electronic GPS monitoring. Ms. Maxwell, for personal reasons, will continue to need security guards to protect her upon release. Under the circumstances, if the Court requires it, the security guards could report to Pretrial Services.16
+
+<sup>16</sup> In United States v. Houston!, 932 F.3d 79 (2d Cir. 2019), the Second Circuit curtailed the circumstances under which a court can grant pretrial release to a defendant on the condition that the defendant pays for private armed security guards. Boustani, nevertheless, held that a defendant may be released on such a condition if the defendant "is deemed to be a flight risk primarily because of his wealth. In other words, a defendant may be released on such a condition only where, but for his wealth, he would not have been detained." Id. (emphasis in original). We submit that a similarly situated defendant who, like Ms. Maxwell, had no prior criminal record, significant ties to the United States, and a demonstrated lack of intent to flee the country, as well as numerous, supportive co-signers, but who did
+
+Ms. Maxwell has a number of other family members and friends who, under normal circumstances, would also co-sign and secure her bond. She is not relying on them in connection with this bail application in an effort to safeguard their privacy and protect them and their families from harm.
+
+The proposed bail conditions are consistent with those approved by courts in this Circuit in other high-profile cases, and should be approved here. See, e.g., United States v. Esposito, 309 F. Supp. 3d 24, 32 (S.D.N.Y. 2018) (alleged leader of Genovese crime family who was charged with racketeering and extortion granted release subject to conditions), aff'd, 749 F. App'x 20 (2d Cir. 2018); United States v. Dreier, 596 F. Supp. 2d 831, 832 (S.D.N.Y. 2009) (Marc Dreier, accused of "colossal criminality" and alleged to be a "high flight risk," granted release subject to conditions); United States v. Madoff, 586 F. Supp. 2d 240, 243 (S.D.N.Y. 2009) (Bernie Madoff, charged with "largest Ponzi scheme ever and alleged to be a "serious risk of flight," granted release subject to conditions).
+
+not have Ms. Maxwell's means, would be released on bail conditions. Accordingly, if the Court deems it necessary, it may impose private security guards as a condition of release.
+
+### CONCLUSION
+
+For the foregoing reasons, Ms. Maxwell respectfully requests that the Court order her release on bail pursuant to the conditions she has proposed.
+
+Dated: July 10, 2020
+
+Respectfully submitted,
+
+/s/ Mark S. Cohen
+
+Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: 212-957-7600
+
+Jeffrey S. Pagliuca (pro hac vice admission pending) Laura A. Menninger HADDON, MORGAN & FORMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: 303-831-7364
+
+Attorneys for Ghislaine Maxwell

marker2/ds9/EFTA00083324/EFTA00083324.metadata.json

@@ -0,0 +1,1339 @@
+{
+  "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083324.pdf",
+  "engine": {
+    "marker_major": "2",
+    "marker_version": "2.0.0",
+    "mode": "balanced",
+    "use_llm": false,
+    "force_ocr": false,
+    "disable_ocr": false,
+    "output_format": "markdown",
+    "preserve_source": false
+  },
+  "fingerprint": "d889ea60d5548ac4",
+  "pages": 26,
+  "chars": 52975,
+  "elapsed_seconds": 8.74,
+  "image_assets": [],
+  "marker_metadata": {
+    "table_of_contents": [
+      {
+        "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK",
+        "heading_level": null,
+        "page_id": 0,
+        "polygon": [
+          [
+            68.544,
+            71.28
+          ],
+          [
+            281.419189453125,
+            71.28
+          ],
+          [
+            281.419189453125,
+            99.7330322265625
+          ],
+          [
+            68.544,
+            99.7330322265625
+          ]
+        ]
+      },
+      {
+        "title": "MEMORANDUM OF GHISLAINE MAXWELL \nIN OPPOSITION TO THE GOVERNMENT'S MOTION FOR DETENTION",
+        "heading_level": null,
+        "page_id": 0,
+        "polygon": [
+          [
+            102.81600000000002,
+            332.90999999999997
+          ],
+          [
+            508.8299560546875,
+            332.90999999999997
+          ],
+          [
+            508.8299560546875,
+            361.4830322265625
+          ],
+          [
+            102.81600000000002,
+            361.4830322265625
+          ]
+        ]
+      },
+      {
+        "title": "TABLE OF CONTENTS",
+        "heading_level": null,
+        "page_id": 1,
+        "polygon": [
+          [
+            238.68,
+            71.28
+          ],
+          [
+            374.134521484375,
+            71.28
+          ],
+          [
+            374.134521484375,
+            86.2330322265625
+          ],
+          [
+            238.68,
+            86.2330322265625
+          ]
+        ]
+      },
+      {
+        "title": "TABLE OF AUTHORITIES",
+        "heading_level": null,
+        "page_id": 2,
+        "polygon": [
+          [
+            228.88800000000003,
+            72.08999999999999
+          ],
+          [
+            383.6007995605469,
+            72.08999999999999
+          ],
+          [
+            383.6007995605469,
+            85.8170166015625
+          ],
+          [
+            228.88800000000003,
+            85.8170166015625
+          ]
+        ]
+      },
+      {
+        "title": "PRELIMINARY STATEMENT",
+        "heading_level": null,
+        "page_id": 4,
+        "polygon": [
+          [
+            219.70799999999997,
+            72.08999999999999
+          ],
+          [
+            391.927978515625,
+            72.08999999999999
+          ],
+          [
+            391.927978515625,
+            86.103515625
+          ],
+          [
+            219.70799999999997,
+            86.103515625
+          ]
+        ]
+      },
+      {
+        "title": "ARGUMENT",
+        "heading_level": null,
+        "page_id": 8,
+        "polygon": [
+          [
+            264.996,
+            263.25
+          ],
+          [
+            346.6669616699219,
+            263.25
+          ],
+          [
+            346.6669616699219,
+            278.853515625
+          ],
+          [
+            264.996,
+            278.853515625
+          ]
+        ]
+      },
+      {
+        "title": "I. The Conditions Created by the COVID-19 Pandemic Mandate the Release of \nMs. Maxwell.",
+        "heading_level": null,
+        "page_id": 8,
+        "polygon": [
+          [
+            67.932,
+            509.49
+          ],
+          [
+            525.9310913085938,
+            509.49
+          ],
+          [
+            525.9310913085938,
+            539.5670471191406
+          ],
+          [
+            67.932,
+            539.5670471191406
+          ]
+        ]
+      },
+      {
+        "title": "II. The Government Has Not Carried Its Burden Under 18 U.S.C. \u00a7 3142.",
+        "heading_level": null,
+        "page_id": 12,
+        "polygon": [
+          [
+            68.544,
+            153.09
+          ],
+          [
+            488.9875183105469,
+            153.09
+          ],
+          [
+            488.9875183105469,
+            168.603515625
+          ],
+          [
+            68.544,
+            168.603515625
+          ]
+        ]
+      },
+      {
+        "title": "A. Applicable Law",
+        "heading_level": null,
+        "page_id": 12,
+        "polygon": [
+          [
+            105.26399999999998,
+            289.17
+          ],
+          [
+            232.03756713867188,
+            289.17
+          ],
+          [
+            232.03756713867188,
+            305.10357666015625
+          ],
+          [
+            105.26399999999998,
+            305.10357666015625
+          ]
+        ]
+      },
+      {
+        "title": "B. Ms. Maxwell Has Rebutted the Presumption That She Poses a Flight \nRisk, and the Government Has Not Carried Its Burden That No \nCombination of Conditions Can Be Imposed To Reasonably Assure Her \nPresence In Court",
+        "heading_level": null,
+        "page_id": 14,
+        "polygon": [
+          [
+            104.652,
+            373.40999999999997
+          ],
+          [
+            533.2659301757812,
+            373.40999999999997
+          ],
+          [
+            533.2659301757812,
+            431.1035461425781
+          ],
+          [
+            104.652,
+            431.1035461425781
+          ]
+        ]
+      },
+      {
+        "title": "1. Ms. Maxwell's Personal History and Characteristics \nDemonstrate That She Is Not a Flight Risk",
+        "heading_level": null,
+        "page_id": 15,
+        "polygon": [
+          [
+            140.76,
+            71.28
+          ],
+          [
+            464.15997314453125,
+            71.28
+          ],
+          [
+            464.15997314453125,
+            99.7330322265625
+          ],
+          [
+            140.76,
+            99.7330322265625
+          ]
+        ]
+      },
+      {
+        "title": "2. The Nature and Circumstances of the Charges and the \nWeight of the Evidence Militate in Favor of Bail",
+        "heading_level": null,
+        "page_id": 20,
+        "polygon": [
+          [
+            140.148,
+            374.22
+          ],
+          [
+            476.5834655761719,
+            374.22
+          ],
+          [
+            476.5834655761719,
+            403.4830322265625
+          ],
+          [
+            140.148,
+            403.4830322265625
+          ]
+        ]
+      },
+      {
+        "title": "3. The Proposed Bail Package Is More Than \nAdequate to Secure Ms. Maxwell's Presence",
+        "heading_level": null,
+        "page_id": 23,
+        "polygon": [
+          [
+            140.148,
+            71.28
+          ],
+          [
+            420.64044189453125,
+            71.28
+          ],
+          [
+            420.64044189453125,
+            99.603515625
+          ],
+          [
+            140.148,
+            99.603515625
+          ]
+        ]
+      },
+      {
+        "title": "CONCLUSION",
+        "heading_level": null,
+        "page_id": 25,
+        "polygon": [
+          [
+            261.936,
+            72.08999999999999
+          ],
+          [
+            349.4591369628906,
+            72.08999999999999
+          ],
+          [
+            349.4591369628906,
+            86.2330322265625
+          ],
+          [
+            261.936,
+            86.2330322265625
+          ]
+        ]
+      }
+    ],
+    "page_stats": [
+      {
+        "page_id": 0,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            55
+          ],
+          [
+            "Line",
+            27
+          ],
+          [
+            "Text",
+            5
+          ],
+          [
+            "SectionHeader",
+            2
+          ],
+          [
+            "PageHeader",
+            1
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 1,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            41
+          ],
+          [
+            "Line",
+            21
+          ],
+          [
+            "PageFooter",
+            2
+          ],
+          [
+            "PageHeader",
+            1
+          ],
+          [
+            "SectionHeader",
+            1
+          ],
+          [
+            "TableOfContents",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 2,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            69
+          ],
+          [
+            "Line",
+            34
+          ],
+          [
+            "PageFooter",
+            2
+          ],
+          [
+            "PageHeader",
+            1
+          ],
+          [
+            "SectionHeader",
+            1
+          ],
+          [
+            "TableOfContents",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 3,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            68
+          ],
+          [
+            "Line",
+            33
+          ],
+          [
+            "PageFooter",
+            2
+          ],
+          [
+            "PageHeader",
+            1
+          ],
+          [
+            "TableOfContents",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 4,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            51
+          ],
+          [
+            "Line",
+            26
+          ],
+          [
+            "Text",
+            3
+          ],
+          [
+            "PageHeader",
+            1
+          ],
+          [
+            "SectionHeader",
+            1
+          ],
+          [
+            "PageFooter",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 5,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            51
+          ],
+          [
+            "Line",
+            26
+          ],
+          [
+            "Text",
+            2
+          ],
+          [
+            "PageFooter",
+            2
+          ],
+          [
+            "PageHeader",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 6,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            53
+          ],
+          [
+            "Line",
+            26
+          ],
+          [
+            "Text",
+            4
+          ],
+          [
+            "PageFooter",
+            2
+          ],
+          [
+            "PageHeader",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 7,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            52
+          ],
+          [
+            "Line",
+            26
+          ],
+          [
+            "Text",
+            3
+          ],
+          [
+            "PageFooter",
+            2
+          ],
+          [
+            "PageHeader",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 8,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            54
+          ],
+          [
+            "Line",
+            27
+          ],
+          [
+            "Text",
+            5
+          ],
+          [
+            "SectionHeader",
+            2
+          ],
+          [
+            "PageFooter",
+            2
+          ],
+          [
+            "PageHeader",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 9,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            72
+          ],
+          [
+            "Line",
+            30
+          ],
+          [
+            "Text",
+            3
+          ],
+          [
+            "Footnote",
+            3
+          ],
+          [
+            "PageFooter",
+            2
+          ],
+          [
+            "PageHeader",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 10,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            57
+          ],
+          [
+            "Line",
+            26
+          ],
+          [
+            "Text",
+            3
+          ],
+          [
+            "Footnote",
+            2
+          ],
+          [
+            "PageFooter",
+            2
+          ],
+          [
+            "PageHeader",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 11,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            68
+          ],
+          [
+            "Line",
+            34
+          ],
+          [
+            "Text",
+            3
+          ],
+          [
+            "Footnote",
+            2
+          ],
+          [
+            "PageFooter",
+            2
+          ],
+          [
+            "PageHeader",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 12,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            59
+          ],
+          [
+            "Line",
+            28
+          ],
+          [
+            "Text",
+            3
+          ],
+          [
+            "SectionHeader",
+            2
+          ],
+          [
+            "PageFooter",
+            2
+          ],
+          [
+            "PageHeader",
+            1
+          ],
+          [
+            "Footnote",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 13,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            51
+          ],
+          [
+            "Line",
+            26
+          ],
+          [
+            "Text",
+            4
+          ],
+          [
+            "PageFooter",
+            2
+          ],
+          [
+            "PageHeader",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 14,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            52
+          ],
+          [
+            "Line",
+            26
+          ],
+          [
+            "Text",
+            2
+          ],
+          [
+            "PageFooter",
+            2
+          ],
+          [
+            "PageHeader",
+            1
+          ],
+          [
+            "SectionHeader",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 15,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            56
+          ],
+          [
+            "Line",
+            28
+          ],
+          [
+            "ListGroup",
+            2
+          ],
+          [
+            "Text",
+            2
+          ],
+          [
+            "PageFooter",
+            2
+          ],
+          [
+            "ListItem",
+            2
+          ],
+          [
+            "PageHeader",
+            1
+          ],
+          [
+            "SectionHeader",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 16,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            69
+          ],
+          [
+            "Line",
+            30
+          ],
+          [
+            "Text",
+            2
+          ],
+          [
+            "PageFooter",
+            2
+          ],
+          [
+            "PageHeader",
+            1
+          ],
+          [
+            "Footnote",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 17,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            55
+          ],
+          [
+            "Line",
+            27
+          ],
+          [
+            "Text",
+            3
+          ],
+          [
+            "PageFooter",
+            2
+          ],
+          [
+            "PageHeader",
+            1
+          ],
+          [
+            "ListGroup",
+            1
+          ],
+          [
+            "ListItem",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 18,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            56
+          ],
+          [
+            "Line",
+            28
+          ],
+          [
+            "Text",
+            3
+          ],
+          [
+            "Footnote",
+            2
+          ],
+          [
+            "PageFooter",
+            2
+          ],
+          [
+            "PageHeader",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 19,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            57
+          ],
+          [
+            "Line",
+            28
+          ],
+          [
+            "Text",
+            3
+          ],
+          [
+            "PageFooter",
+            2
+          ],
+          [
+            "PageHeader",
+            1
+          ],
+          [
+            "Footnote",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 20,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            74
+          ],
+          [
+            "Line",
+            30
+          ],
+          [
+            "Text",
+            2
+          ],
+          [
+            "PageFooter",
+            2
+          ],
+          [
+            "PageHeader",
+            1
+          ],
+          [
+            "SectionHeader",
+            1
+          ],
+          [
+            "Footnote",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 21,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            61
+          ],
+          [
+            "Line",
+            30
+          ],
+          [
+            "Text",
+            2
+          ],
+          [
+            "PageFooter",
+            2
+          ],
+          [
+            "PageHeader",
+            1
+          ],
+          [
+            "Footnote",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 22,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            51
+          ],
+          [
+            "Line",
+            24
+          ],
+          [
+            "Text",
+            2
+          ],
+          [
+            "PageFooter",
+            2
+          ],
+          [
+            "PageHeader",
+            1
+          ],
+          [
+            "Footnote",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 23,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            61
+          ],
+          [
+            "Line",
+            30
+          ],
+          [
+            "Text",
+            2
+          ],
+          [
+            "PageFooter",
+            2
+          ],
+          [
+            "PageHeader",
+            1
+          ],
+          [
+            "SectionHeader",
+            1
+          ],
+          [
+            "Footnote",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 24,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            35
+          ],
+          [
+            "Line",
+            18
+          ],
+          [
+            "Text",
+            2
+          ],
+          [
+            "PageFooter",
+            2
+          ],
+          [
+            "PageHeader",
+            1
+          ],
+          [
+            "Footnote",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 25,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            45
+          ],
+          [
+            "Line",
+            23
+          ],
+          [
+            "Text",
+            7
+          ],
+          [
+            "PageFooter",
+            2
+          ],
+          [
+            "PageHeader",
+            1
+          ],
+          [
+            "SectionHeader",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      }
+    ],
+    "debug_data_path": "debug_data/EFTA00083324"
+  }
+}

marker2/ds9/EFTA00083350/EFTA00083350.md

@@ -0,0 +1,45 @@
+## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+
+United States of America,
+
+—v—
+
+Ghislaine Maxwell,
+
+Defendant.
+
+USDC SONY DOCUMENT ELECTRONICALLY FILED DOC 0: DATE FILED: 12/28/20
+
+20-CR-330 (MN)
+
+ORDER
+
+ALISON J. NATHAN, District Judge:
+
+On December 8, 2020, Defendant Ghislaine Maxwell filed a renewed motion for release on bail. Dkt No. 97. In an Opinion and Order concurrently filed under temporary seal, the Court DENIES the Defendant's motion.
+
+In light of the fact that the Opinion includes potentially confidential information that should not be filed on the public docket, the Court will permit the parties 48 hours to propose any redactions to the Court's Opinion and Order and to justify those redactions by reference to the Second Circuit's decision in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110(2d Cir. 2006). After determining which, if any, portions of the Opinion and Order should be redacted, the Court will file the Opinion and Order on the public docket.
+
+This Order provides the bottom line of the Court's resolution. On July 14, 2020, this Court conducted an extensive bail hearing and determined that pre-trial detention was warranted because the no conditions or set of conditions could reasonably assure the Defendant's appearance at future proceedings. Under 18 U.S.C. § 3142(0, a bail hearing may be reopened if the Court finds "that information exists that was not known to the movant at the time of the hearing and that has a material bearing on the issue whether there are conditions of release that will reasonably assure the appearance of such person as required." The Court concludes that
+
+none of the new information that the Defendant presented in support of her application has a material bearing on the Court's determination that she poses a flight risk.
+
+Furthermore, for substantially the same reasons as the Court determined that detention was warranted in the initial bail hearing, the Court again concludes that no conditions of release can reasonably assure the Defendant's appearance at future proceedings. In reaching that conclusion, the Court considers the nature and circumstances of the offenses charged, the weight of the evidence against the Defendant, the history and characteristics of the Defendant, and the nature and seriousness of the danger that the Defendant's release would pose. *See* 18 U.S.C. § 3142(g). The Government does not contend that the Defendant poses a danger to the community. Nonetheless the Court determines that the other three factors warrant detention under 18 U.S.C. § 3142(e). The Court also finds that the Defendant's proposed bail conditions would not reasonably assure her appearance at future proceedings.
+
+As a result, the Court concludes that the Government has met its burden of persuasion that the Defendant poses a flight risk and that pre-trial detention continues to be warranted.
+
+On or before December 30, 2020, the parties are ORDERED to submit a joint letter indicating whether they propose any redactions and the justification for any such proposal.
+
+This resolves Dkt No. 97.
+
+SO ORDERED.
+
+Dated: December 28, 2020  
+New York, New York
+
+![]()
+
+---
+
+ALISON J. NATHAN  
+United States District Judge

marker2/ds9/EFTA00083350/EFTA00083350.metadata.json

@@ -0,0 +1,116 @@
+{
+  "source_pdf": "/home/robbd/my/apps/epstein-index/data/raw/ds9/EFTA00083350.pdf",
+  "engine": {
+    "marker_major": "2",
+    "marker_version": "2.0.0",
+    "mode": "balanced",
+    "use_llm": false,
+    "force_ocr": false,
+    "disable_ocr": false,
+    "output_format": "markdown",
+    "preserve_source": false
+  },
+  "fingerprint": "d889ea60d5548ac4",
+  "pages": 2,
+  "chars": 3214,
+  "elapsed_seconds": 5.71,
+  "image_assets": [],
+  "marker_metadata": {
+    "table_of_contents": [
+      {
+        "title": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK",
+        "heading_level": null,
+        "page_id": 0,
+        "polygon": [
+          [
+            68.544,
+            71.28
+          ],
+          [
+            281.8329772949219,
+            71.28
+          ],
+          [
+            281.8329772949219,
+            99.603515625
+          ],
+          [
+            68.544,
+            99.603515625
+          ]
+        ]
+      }
+    ],
+    "page_stats": [
+      {
+        "page_id": 0,
+        "text_extraction_method": "pdftext",
+        "block_counts": [
+          [
+            "Span",
+            63
+          ],
+          [
+            "Line",
+            32
+          ],
+          [
+            "Text",
+            11
+          ],
+          [
+            "PageFooter",
+            2
+          ],
+          [
+            "SectionHeader",
+            1
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      },
+      {
+        "page_id": 1,
+        "text_extraction_method": "surya",
+        "block_counts": [
+          [
+            "Span",
+            45
+          ],
+          [
+            "Line",
+            23
+          ],
+          [
+            "Text",
+            16
+          ],
+          [
+            "PageFooter",
+            4
+          ],
+          [
+            "Caption",
+            2
+          ]
+        ],
+        "block_metadata": {
+          "llm_request_count": 0,
+          "llm_error_count": 0,
+          "llm_tokens_used": 0,
+          "previous_text": "",
+          "previous_type": "",
+          "previous_order": 0
+        }
+      }
+    ],
+    "debug_data_path": "debug_data/EFTA00083350"
+  }
+}