Epstein Secrets

ority of the bars that might be relied upon by Ms Maxwells require the extradition judge to make a finding

ts, a review that formed the basis of changes to the 2003 Extradition Act. (Id. Annex B ¶ 3.1). In Mr. Perry's opinion, it is "highly unlikely that Ghislaine Maxwell would be able successfully to resist extradition to the United States" in connection with this case. (Perry Rep. 12(e)). After concluding that none

ide any answer on this issue. 2 The DOJ Memorandum and the Peterson Case In support of its argument that the French government would not extradite Ms Ghislaine Maxwell to the USA, the government relies on the case of Mr Hans Peterson, a dual French American citizen whose extradition to the US was denied by

seding indictment dated 7 July 2020. In addition to those conclusions, the following three points may be made. 3. First, as noted in the Opinion2, Ms Maxwell's waiver of extradition would be admissible in any extradition proceedings in England and Wales. While such a document cannot compel a requested pers

r, CO 80203 Phone: Bobbi C. Sternheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, NY 10011 Phone: Attorneys for Ghislaine Maxwell II EFTA00093319 cailase:20-agloDacument ntlinfiAtIllf0891, 806E128B2Blage34figrl 3tI 4 Exhibit A EFTA00093320 Ckast.20-U-0003.00dblit DOditrehlei

eciality (s. 95); (c) earlier extradition to the United Kingdom from another territory (s. 96); and (d) earlier transfer to the United Kingdom from the International Criminal Court (s. 96A). 7 Extradition Act 2003, s. 93(4Xa). EFTA00093326 Cianst:20-?1-0130304/430/1 Ebbdinfitill100221, 80682BB213 213agil 351 4 another stat

ion is provided pursuant to instructions from Peters and Peters Solicitors LLP I dated 12 August 2020 in the context of bail proceedings relating to Ms Ghislaine Maxwell before the United States District Court, Southern District of New York. Subsequent instructions have confirmed that Ms Maxwell will execute a waive

of time since the alleged commission of the offences62. The courts have upheld orders for extradition in cases with similar timescales to those in Ms Maxwell's case, including two cases involving historic allegations of sexual offending where the relevant time period was 20 and 33 years. In both cases, the

d States prior to trial and in breach of bail. The following documents were annexed to the instructions: (a) Superseding Indictment United States v Ghislaine Maxwell dated 8 July 2020; (b) a transcript of the arraignment and bail hearing that took place on 14 July 2020; (c) the Motion to Detain the Defen

rior to trial and in breach of bail. The following documents were annexed to the instructions: (a) Superseding Indictment United States v Ghislaine Maxwell dated 8 July 2020; (b) a transcript of the arraignment and bail hearing that took place on 14 July 2020; (c) the Motion to Detain the Defendant date

eciality (s. 95); (c) earlier extradition to the United Kingdom from another territory (s. 96); and (d) earlier transfer to the United Kingdom from the International Criminal Court (s. 96A). is Extradition Act 2003, s. 70(11). 1922623.1 4 EFTA00065606 9. A requested person may appeal the decision of the appropriate judge

he European Court of Human Rights Part II — The likely outcome of an extradition request from the United States of America to France in the case of Ms Ghislaine Maxwell A. General bars to extradition B. The protection of nationals from extradition under French law and the Extradition Treaty between the USA and France:

nal ties of Ms Ghislaine Maxwell and her French nationality appear as one of the grounds for which bail was denied by the Court, which found that: "Ms Maxwell's history and characteristics support the position of her posing a risk of flight. Ms Maxwell has substantial international ties and could facilitate

she has signed an irrevocable Waiver in the USA; the fact that in the present situation, the only way the issue would be raised in France is if Ms. Maxwell would have already fled to France in violation of very strict bail conditions, and the fact that a failure by French authorities to grant extraditio

ection of nationals from extradition in the French legal system and in the Extradition Treaty between the USA and France (B). It will conclude that Ms Ghislaine Maxwell's extradition from France to the USA would not be legally barred by her French citizenship, and that it is highly unlikely, under the specif

is mandate. By contrast, the provisions of the Rome Statute which require Contracting Parties to surrender their nationals when the jurisdiction of the International Criminal Court is established did not trigger an amendment to the French Constitution. Like the EAW FD, the example of the Rome Statute must be taken as evidence

ion is provided pursuant to instructions from Peters and Peters Solicitors LLP I dated 12 August 2020 in the context of bail proceedings relating to Ms Ghislaine Maxwell before the United States District Court, Southern District of New York. Subsequent instructions have confirmed that Ms Maxwell will execute a waive

of time since the alleged commission of the offences62. The courts have upheld orders for extradition in cases with similar timescales to those in Ms Maxwell's case, including two cases involving historic allegations of sexual offending where the relevant time period was 20 and 33 years. In both cases, the

d States prior to trial and in breach of bail. The following documents were annexed to the instructions: (a) Superseding Indictment United States v Ghislaine Maxwell dated 8 July 2020; (b) a transcript of the arraignment and bail hearing that took place on 14 July 2020; (c) the Motion to Detain the Defen

rior to trial and in breach of bail. The following documents were annexed to the instructions: (a) Superseding Indictment United States v Ghislaine Maxwell dated 8 July 2020; (b) a transcript of the arraignment and bail hearing that took place on 14 July 2020; (c) the Motion to Detain the Defendant date

eciality (s. 95); (c) earlier extradition to the United Kingdom from another territory (s. 96); and (d) earlier transfer to the United Kingdom from the International Criminal Court (s. 96A). is Extradition Act 2003, s. 70(11). 1922623.1 4 EFTA00073550 9. A requested person may appeal the decision of the appropriate judge

Exhibit B EFTA00074068 IN THE MATTER OF AN OPINION ON THE EXTRADITION LAW OF ENGLAND AND WALES RE GHISLAINE MAXWELL ADDENDUM OPINION 1. This Addendum Opinion is provided in response to the Government's Memorandum in Opposition to the Defendant's Renewed Motion

ngs in the United States prior to trial and in breach of bail; and (c) on the basis of the information currently known, it is highly unlikelyt that Ghislaine Maxwell would be able successfully to resist extradition to the United States in relation to the charges in the superseding indictment dated 7 July 2020. I

seding indictment dated 7 July 2020. In addition to those conclusions, the following three points may be made. 3. First, as noted in the Opinion2, Ms Maxwell's waiver of extradition would be admissible in any extradition proceedings in England and Wales. While such a document cannot compel a requested pers

ON THE EXTRADITION LAW OF ENGLAND AND WALES RE GHISLAINE MAXWELL ADDENDUM OPINION 1. This Addendum Opin

eciality (s. 95); (c) earlier extradition to the United Kingdom from another territory (s. 96); and (d) earlier transfer to the United Kingdom from the International Criminal Court (s. 96A). 7 Extradition Act 2003, s. 93(4)(a). EFTA00074070 another states; (d) the person has been granted asylum or humanitarian protection in

he European Court of Human Rights Part II — The likely outcome of an extradition request from the United States of America to France in the case of Ms Ghislaine Maxwell A. General bars to extradition B. The protection of nationals from extradition under French law and the Extradition Treaty between the USA and France:

nal ties of Ms Ghislaine Maxwell and her French nationality appear as one of the grounds for which bail was denied by the Court, which found that: "Ms Maxwell's history and characteristics support the position of her posing a risk of flight. Ms Maxwell has substantial international ties and could facilitate

she has signed an irrevocable Waiver in the USA; the fact that in the present situation, the only way the issue would be raised in France is if Ms. Maxwell would have already fled to France in violation of very strict bail conditions, and the fact that a failure by French authorities to grant extraditio

ection of nationals from extradition in the French legal system and in the Extradition Treaty between the USA and France (B). It will conclude that Ms Ghislaine Maxwell's extradition from France to the USA would not be legally barred by her French citizenship, and that it is highly unlikely, under the specif

is mandate. By contrast, the provisions of the Rome Statute which require Contracting Parties to surrender their nationals when the jurisdiction of the International Criminal Court is established did not trigger an amendment to the French Constitution. Like the EAW FD, the example of the Rome Statute must be taken as evidence

ion is provided pursuant to instructions from Peters and Peters Solicitors LLP I dated 12 August 2020 in the context of bail proceedings relating to Ms Ghislaine Maxwell before the United States District Court, Southern District of New York. Subsequent instructions have confirmed that Ms Maxwell will execute a waive

of time since the alleged commission of the offences62. The courts have upheld orders for extradition in cases with similar timescales to those in Ms Maxwell's case, including two cases involving historic allegations of sexual offending where the relevant time period was 20 and 33 years. In both cases, the

d States prior to trial and in breach of bail. The following documents were annexed to the instructions: (a) Superseding Indictment United States v Ghislaine Maxwell dated 8 July 2020; (b) a transcript of the arraignment and bail hearing that took place on 14 July 2020; (c) the Motion to Detain the Defen

rior to trial and in breach of bail. The following documents were annexed to the instructions: (a) Superseding Indictment United States v Ghislaine Maxwell dated 8 July 2020; (b) a transcript of the arraignment and bail hearing that took place on 14 July 2020; (c) the Motion to Detain the Defendant date

eciality (s. 95); (c) earlier extradition to the United Kingdom from another territory (s. 96); and (d) earlier transfer to the United Kingdom from the International Criminal Court (s. 96A). is Extradition Act 2003, s. 70(11). 1922623.1 4 EFTA00154418 9. A requested person may appeal the decision of the appropriate judge

ngs in the United States prior to trial and in breach of bail; and (c) on the basis of the information currently known, it is highly unlikely' that Ghislaine Maxwell would be able successfully to resist extradition to the United States in relation to the charges in the superseding indictment dated 7 July 2020. I

ion currently known, it is highly unlikely' that Ghislaine Maxwell would be able successfully to resist ext

ail would almost certainly be refused for the duration of the extradition proceedings. (b) The majority of the bars that might be relied upon by Ms Maxwells require the extradition judge to make a finding that extradition would be oppressive. Quite apart from the other factors rendering those bars unav

eciality (s. 95); (c) earlier extradition to the United Kingdom from another territory (s. 96); and (d) earlier transfer to the United Kingdom from the International Criminal Court (s. 96A). 7 Extradition Act 2003, s. 93(4Xa). EFTA00016790 --- PAGE BREAK --- another states; (d) the person has been granted asylum or humanita

In order to assure the US authorities that she will not attempt to contest her extradition as a French citizen or otherwise, we are informed that Ms Maxwell is about to execute an irrevocable waiver of her right to seek the protection of the French Courts to fight • 75017 paris • tel. — fax. www.wjavo

William JULIE avocet a la cour— attorney at law Ghislaine Maxwell Opinion on French Extradition Law OVERV

ly way the issue would be raised in France is if Ms. Maxwell would have already fled to France in violation of

the time remaining to be served must be at least six months." 41. There is no doubt that the conduct referred to in the Grand Jury charges against Ms Ghislaine Maxwell, contained in the Superseding Indictment SI 20 Cr. 330 (AJN), filed on July 8th, 2020, also constitutes criminal conduct under French law, as the cr