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den of production, the presumption "remains a factor to be considered among those weighed by the district court." Mercedes, 254 F.3d at 436 (quoting Martir, 782 F.2d at 1144). The Court is mindful "that Congress has found that these offenders pose special risks of flight, and that `a strong probability
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
the evidence that the defendant presents a risk of flight:" English, 629 F.3d at 319 (quoting Mercedes, 254 F.3d at 436); see also United States v. Martir, 782 F.2d 1141, 1144 (2d Cir. 1986) ("The government retains the burden of persuasion tin a presumption case]."). Even when "a defendant has met hi
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
"remains a factor to be considered among those weighed by the district court." United States v. Mercedes, 254 F.3d 433, 436 (2d Cir. 2001) (quoting Martir, 782 F.2d at 1144). As a result, "[a] judicial officer conducting a detention hearing should, even after a defendant has come forward with rebuttal
Page: EFTA00013314 →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 Martir and the French Ministry of Justice

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSON
United Kingdom
LOCATION
Contreras
PERSONthe Southern District
LOCATIONSecond Circuit
ORGANIZATION
Southern District of New York
ORGANIZATION
Alfredo Rodriguez
PERSONRaniere
PERSONPetrov
PERSONBoustani
PERSON
Mattis
PERSONJessup
LOCATION
Bernie Madoff
PERSONMarc Dreier
PERSONPretrial Services
ORGANIZATION
New York
LOCATIONKarni
PERSONMorrison
PERSON