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he Court emphasized in its denial of the second motion for release on bail, the discrepancies between the information presented to the Court and to Pretrial Services in July 2020 and the information presented to the Court in December 2020 raised significant concerns about candor. See Dec. Op. at 16. There remain
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
d be limited to appearances in Court, meetings with 5 EFTA00013311 --- PAGE BREAK --- counsel, medical visits, and upon approval by the Court or Pretrial Services. Id. at 2-3. Furthermore, the Defendant would have on-premises security guards that she would pay for who would prevent her from leaving the reside
Page: EFTA00013312 →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 →rincipal reasons for denying bail. Rather than question the report itself, the government attempts to argue that Ms. Maxwell deceived the Court and Pretrial Services about her assets. (Gov. Mem. at 22-23). 5 EFTA00016777 --- PAGE BREAK --- The report shows nothing of the sort. Ms. Maxwell, who was sitting in
Page: EFTA00016778 →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
Page: EFTA00016780 →rincipal reasons for denying bail. Rather than question the report itself, the government attempts to argue that Ms. Maxwell deceived the Court and Pretrial Services about her assets. (Gov. Mem. at 22-23). 5 EFTA00019299 --- PAGE BREAK --- The report shows nothing of the sort. Ms. Maxwell, who was sitting in
Page: EFTA00019300 →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
Page: EFTA00019302 →reside with her and serve as an additional residential custodian. EFTA00031919 --- PAGE BREAK --- residence without pre-approval by the Court or Pretrial Services and to escort her when authorized to leave the residence; ■ Visitors to be pre-approved by Pretrial Services: • Strict supervision by Pretrial Se
Page: EFTA00031920 →e de droll penal et de procedure penale Extradition Pa. - Conditions de fond de l'estradition Delphine Brach-Thiel-October 2t I 8„f59). 18. Third, the French Ministry of Justice's interpretation is contradicted by precedents and case law 19. The French Ministry of Justice's interpretation finds no support in case law, as no
Page: EFTA00031933 →Entities connected to both Pretrial Services and the French Ministry of Justice

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSON
Michael Cohen
PERSONthe Southern District
LOCATION
United Kingdom
LOCATIONJeffrey Pagliuca
PERSONFBI
ORGANIZATIONBoustani
PERSON
Southern District of New York
ORGANIZATIONSecond Circuit
ORGANIZATIONCohen & Gresser LLP
ORGANIZATION
New York
LOCATIONMark S. Cohen
PERSON
Denver
LOCATIONMorrison
PERSONStroh
PERSON
Bernie Madoff
PERSONMarc Dreier
PERSON
Contreras
PERSON