5
Shared Docs
5
Same-Page
6 / 8
Mentions
he court in Cirillo did not mention in its opinion"). 15 EFTA00103397 the jurisdiction of her choosing (te., the one to which she chose to flee). The Department of Justice's Office of International Affairs ("OIA") is unaware of any country anywhere in the world that would consider an anticipatory extradition waiver bindi
5, 2000 WL 1872012 (6th Cir. Dec. 12, 2000) 19 United States v. Patrick Ho, 17 Cr. 779 (KBF), Dkt. 49 (S.D.N.Y. Feb. 4, 2018) 28 United States v. Petrov, 15 Cr. 66 (LTS), 2015 WL 11022886 (S.D.N.Y. Mar. 26, 2015) 7, 8 United States v. Rowe, 02 Cr. 756 (LMM), 2003 WL 21196846 (S.D.N.Y. May 21, 2003)
rating "that the court overlooked information or incorrectly applied the law," or that failure to reconsider "would constitute manifest injustice." Petrov, 2015 WL 1102286 at *3. DISCUSSION Having already raised numerous arguments in its briefing and oral argument at the initial bail hearing in this
he validity and/or voluntariness of the waiver, and will get to do so in the jurisdiction of her choosing (Le., the one to which she chose to flee). The Department of Justice's Office of International Affairs ("OIA") is unaware of any country anywhere in the world that would consider an anticipatory extradition waiver bindi
ly reject an attempt to reopen a detention hearing where the new information presented is immaterial to the issue of flight risk." United States v. Petrov, 15 Cr. 66 (LTS), 2015 WL 11022886, at *2 (S.D.N.Y. Mar. 26, 2015). Although courts in this Circuit have recognized that "a release order may be rec
ourt overlooked information or 7 EFTA00089161 incorrectly applied the law," or that failure to reconsider "would constitute manifest injustice." Petrov, 2015 WL 1102286 at *3. DISCUSSION Having already raised numerous arguments in its briefing and oral argument at the initial bail hearing in this
st:20-47I70023e4MIstit lacietriterillati2 Eila€16132)96/15%g 0.f932136 the jurisdiction of her choosing (i.e., the one to which she chose to flee). The Department of Justice's Office of International Affairs ("OIA") is unaware of any country anywhere in the world that would consider an anticipatory extradition waiver bindi
5, 2000 WL 1872012 (6th Cir. Dec. 12, 2000) 19 United States v. Patrick Ho, 17 Cr. 779 (KBF), Dkt. 49 (S.D.N.Y. Feb. 4, 2018) 28 United States v. Petrov, 15 Cr. 66 (LTS), 2015 WL 11022886 (S.D.N.Y. Mar. 26, 2015) 7, 8 United States v. Rowe, 02 Cr. 756 (LMM), 2003 WL 21196846 (S.D.N.Y. May 21, 2003)
rating "that the court overlooked information or incorrectly applied the law," or that failure to reconsider "would constitute manifest injustice." Petrov, 2015 WL 1102286 at *3. DISCUSSION Having already raised numerous arguments in its briefing and oral argument at the initial bail hearing in this
sponse in Opposition to Defendant's Third Motion for Release on Bail EFTA00093361 G2ase12207MOGUIvA614 1136tA4M126€ 1 ,Falitiasneaft ePa§et13219 U.S. Department of Justice United States Attorney Southern District of New York The Silvio 1 Mollo Building One Saint Andrew's Plaza New York. New York 10007 March 9, 202
both the United Kingdom and France is little more than window dressing. After receiving the defendant's Third Bail Motion, the Government, through the Department of Justice's Office of International Affairs ("OIA"), contacted the French Ministry of Justice ("MOJ") to understand the impact of the defendant's offer to reno
dered even where the evidence proffered on reconsideration was known to the movant at the time of the original hearing."); see also United States v. Petrov, No. I 5-CR-66- LTS, 2015 WL 11022886, at *3 (S.D.N.Y. Mar. 26, 2015) (noting "Court's inherent authority for reconsideration of the Court's previou
our Honor, there is a real concern here that the defendant could live beyond the reach of extradition indefinitely. The government has spoken with the Department of Justice attach6s in the United Kingdom and France. With respect to France, we have been informed that France will not extradite a French citizen to the Uni
ited States v. Lee, No. CR-99-1417 JP, 2000 WL 36739632 (D.N.M. 2000) 8 United States v. Orta, 760 F.2d 887 (8th Cir. 1985) 35 United States v. Petrov, No. 15-CR-66-LTS, 2015 WL 11022886 (S.D.N.Y. Mar. 26, 2015) 8 United States v. Rowe, No. 02 CR. 756 LMM, 2003 WL 21196846 (S.D.N.Y. May 21, 2003
Entities connected to both Department of Justice and Petrov

Jeffrey Epstein
PERSON
United States
LOCATION
Prince Andrew
PERSONthe Southern District
LOCATION
Ghislaine Maxwell
PERSONSouthern District
LOCATIONFBI
ORGANIZATION
George W. Bush
PERSONFederal Bureau of Prisons
ORGANIZATION
Michael Cohen
PERSON
Stephen Hawking
PERSON
Southern District of New York
ORGANIZATION
Michael Jackson
PERSON
Alfredo Rodriguez
PERSON
Colorado
LOCATION
Audrey Strauss
PERSON
John F. Kennedy
PERSON
Harvey Weinstein
PERSON
Denver
LOCATION
Vicky Ward
PERSON