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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

memorandum: "Article 3 of the Extradition Treaty between the United States and France provides in pertinent part that "There is no obligation upon the Requested State to grant the extradition of a person who is a national of the Requested State". While this Ankle does not require the extradition of a national to

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

Code of Criminal Procedure. 56. Article 3(1) of the Extradition Treaty between France and the United States provides: "There is no obligation upon the Requested State to grant the extradition of a person who is a national of the Requested State, but the executive authority of the United States shall have the powe

ISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, v. 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER THIRD MOTION FOR RAIL Bobbi C. Sternheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York NY

URT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, v. 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x REPLY MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF HER THIRD MOTION FOR RAIL Bobbi C. Sternheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York NY 10011 P

pursuant to a request from Olivier Laude, a partner at the French firm Laude Esquier Champey acting on behalf of Cohen & Gresser LLP as counsel for Ms Ghislaine Maxwell. The request was made in the context of ongoing bail proceedings involving Ms Maxwell in the United States of America (hereafter "USA"), where Ms M

The issue before the Court, as it has been since Ms. Maxwell's first bail application, is whether conditions

nch Code of Criminal Procedure for matters not dealt with under the Treaty. ' 9. Article 3(I) of the Treaty provides: "There is no obligation upon the Requested State to grant the extradition of a person who is a national of the Requested State, but the executive authority of the United States shall have the powe

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

Code of Criminal Procedure. 56. Article 3(1) of the Extradition Treaty between France and the United States provides: "There is no obligation upon the Requested State to grant the extradition of a person who is a national of the Requested State, but the executive authority of the United States shall have the powe

ant presented to the Court at the initial bail hearing was undisputedly incomplete, and as the Court noted, the Court lacked "a clear picture of Ms. Maxwell's finances and the resources available to her." Tr. at 86 87. The Defendant has now presented to the Court what is perhaps a more thorough report o

pursuant to a request from Olivier Laude, a partner at the French firm Laude Esquier Champey acting on behalf of Cohen & Gresser LLP as counsel for Ms Ghislaine Maxwell. The request was made in the context of ongoing bail proceedings involving Ms Maxwell in the United States of America (hereafter "USA"), where Ms M

207a0063390eNt Thaatiallat 1 [email protected] UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA, v. GHISLAINE MAXWELL, Defendant. x 20 Cr. 330 (AJN) MEMORANDUM IN SUPPORT OF GHISLAINE MAXWELL'S THIRD MOTION FOR RELEASE ON BAIL Bobbi C. Sternheim Law Of

Court noted, the Court lacked "a clear picture of Ms. Maxwell's finances and the resources available to her."

rench Code of Criminal Procedure for matters not dealt with under the Treaty. 9. Article 3(1) of the Treaty provides: "There is no obligation upon the Requested State to grant the extradition of a person who is a national of the Requested State, but the executive authority of the United States shall have the powe

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

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 France i

issue and execute an extradition decree against Ms. Maxwell, particularly if Ms. Maxwell has signed an irrevo

s memorandum: "Article 3 of the Extradition Treaty between the United States and France provides in pertinent pan that "There is no obligation upon the Requested State to grant the extradition of a person who is a national of the Requested State". While this Article does not require the extradition of a national t

this basis. 18 U.S.C. § 3142(e)(1). 11 EFTA00104531 Case 1:20-cr-00330-AJN Document 169 Filed 03/22/21 Page 12 of 12 IV. Conclusion Defendant Ghislaine Maxwell's third motion for release on bail, Dkt. No. 160, is DENIED. The parties are ORDERED to meet and confer and propose and justify any redactions to the

EW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTRONICALLY

TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. USDC SDNY DOCUMENT ELECTR

France of April 23, 1996 provides that "[t]here is no obligation upon the Requested State to grant the extradition of a person who is a national of the Requested State, but the executive authority of the United States shall have the power to surrender a national of the United States if, in its discretion, it deems

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