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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
8, 2016 WL 7421924 (W.D.N.Y. Dec. 23, 2016) 15 United States v. Namer, 238 F.3d 425, 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 Un
[t]he government's evidence at this early juncture of the case appears strong" based on the "multiple victims who provided detailed accounts of Ms. Maxwell's involvement in serious crimes," as well as corroboration in the form of "significant contemporaneous documentary evidence." (Id.). Third, the Cou
K x UNITED STATES OF AMERICA 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S MEMORANDUM IN O
K x UNITED STATES OF AMERICA 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S MEMORAN
ltiple victims who provided detailed accounts of Ms. Maxwell's involvement in serious crimes," as well as cor
requent international travel, "minimal" ties to the United States, and "extensive ties to foreign countries without extradition"); United States v. Patrick Ho, 17 Cr. 779 (KBF), Dkt. 49 (S.D.N.Y. Feb. 4, 2018) (ordering defendant detained based on defendant's risk of flight and citing the strength of 28
[t]he government's evidence at this early juncture of the case appears strong" based on the "multiple victims who provided detailed accounts of Ms. Maxwell's involvement in serious crimes," as well as corroboration in the form of "significant contemporaneous documentary evidence." (Id.). Third, the Cou
-x UNITED STATES OF AMERICA 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S MEMORANDUM IN O
-x UNITED STATES OF AMERICA 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S MEMORAN
ltiple victims who provided detailed accounts of Ms. Maxwell's involvement in serious crimes," as well as cor
8, 2016 WL 7421924 (W.D.N.Y. Dec. 23, 2016) 15 United States v. Namer, 238 F.3d 425, 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 Un
section along with about 20 other associates, while additional sections were labeled "Science," "Brooklyn," and "Family." The article explained that Ghislaine Maxwell wrote a prologue and closing note for the book, later telling Justice Department officials she assembled the album but didn't recall who contribute
The article noted the book concluded with a "Next SO Years" section containing a photo of Epstein in a hammock and a message signed "Lots of love, Ghislaine." Additional reporting on the story was provided by ABC News (09/08, Parkinson, Peller), Al Jazeera (09/08, Staff Writer), Associated Press (09/08,
nd "Family." The article explained that Ghislaine Maxwell wrote a prologue and closing note for the book,
e later admitted to leaking sensitive information to an Albanian businessman connected to the Chinese conglomerate CEFC, whose executives, including Patrick Ho, had business dealings with Hunter Biden. Ho was convicted in 2019 of bribery charges unrelated to Biden but had agreed to pay Hunter Biden a $1 mi
Entities connected to both Ghislaine Maxwell and Patrick Ho

Jeffrey Epstein
PERSON
Prince Andrew
PERSONSouthern District
LOCATION
United States
LOCATION
Michael Cohen
PERSON
Department of Justice
ORGANIZATION
Marc Rich
PERSON
Donald Trump
PERSONLeon Black
PERSON
Virginia Giuffre
PERSONFBI
ORGANIZATION
Denver
LOCATIONEmmy Taylor
PERSON
Joe Biden
PERSON
Audrey Strauss
PERSON
David Boies
PERSON
Prince Charles
PERSON
Michael Jackson
PERSON
John F. Kennedy
PERSON
Alfredo Rodriguez
PERSON