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favoring detention does not disappear entirely, but remains a factor to be considered among those weighed by the district court." United States v. Mattis, 963 F.3d 285, 290-91 (2d Cir. 2020). III. Discussion The Defendant bases her third motion for bail on the Court's inherent powers to review its
s on the correct interpretation of French law. The Government relies on the position of the head of the International Criminal Assistance Bureau of the French Ministry of Justice, who argues that "the fact that the wanted individual is a French national constitutes an insuperable obstacle to his/her removal," and that lais lo
favoring detention does not disappear entirely, but remains a factor to be considered among those weighed by the district court." United States v. Mattis, 963 F.3d 285, 290 91 (2d Cir. 2020). After a court has made an initial determination that no conditions of release can reasonably assure the appea
s "highly unlikely" that the French government would refuse to extradite Ms. Maxwell (Def. Mem., Ex. V at 2), the government attaches a letter from the French Ministry of Justice ("MOJ") that references neither Mr. Julie's report nor Ms. Maxwell, but states generally that the French Code of Criminal Procedure "absolutely pro
favoring detention does not disappear entirely, but remains a factor to be considered among those weighed by the district court." United States v. Mattis, 963 F.3d 285, 290-91 (2d Cir. 2020). After a court has made an initial determination that no conditions of release can reasonably assure the appea
Page: EFTA00013310 →r country. See Def. Mot., Exs. T, U, V. As the Government points out in its brief, however, the legal weight of the waivers is, at best, contested. The French Ministry of Justice, for instance, indicated in a letter submitted in conjunction to the Government's opposition that the French Code of Criminal Procedure "absolutely
Page: EFTA00013317 →Entities connected to both Mattis and the French Ministry of Justice

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSON
Michael Cohen
PERSON
United Kingdom
LOCATIONthe Southern District
LOCATION
Barack Obama
PERSONSecond Circuit
ORGANIZATIONBoustani
PERSON
Southern District of New York
ORGANIZATIONMarc Dreier
PERSON
Bernie Madoff
PERSONKarni
PERSONJeffrey Pagliuca
PERSON
Denver
LOCATIONPretrial Services
ORGANIZATIONRaniere
PERSONPetrov
PERSON
Alfredo Rodriguez
PERSONCohen & Gresser LLP
ORGANIZATION