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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
roceedings, the overall uncertainty of the government's evidence"); United States v. Karni, 298 F. Supp. 2d 129, 133 (D.D.C. 2004); United States v. Grillo, No. 99-1514, 1999 WL 1456536, at *2 (3d Cir. July 13, 1999); see also United States v. Georgiou, No. 08-1220- M, 2008 WL 4306750, at *3 (E.D. Pa. S
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. 20-CR-330 (AJN) OPINION AND ORDER ALISON J. NATHAN, District Judge: Defendant Ghislaine Maxwell has been indicted by a grand jury on
Page: EFTA00013307 →TRICT OF NEW YORK United States of America, —v— Ghislaine Maxwell, Defendant. 20-CR-330 (AJN) OPINION AN
Page: EFTA00013307 →islaine Maxwell."); id. ¶ 77 ("[I]t is highly unlikely that the French government would refuse to issue and execute an extradition decree against Ms Maxwell. . . ."). Nor has the Defendant presented any cases where courts addressed the question of whether an anticipatory waiver of extradition is enforce
Page: EFTA00013318 →the reasoning in those cases turned on other factors and the courts did not dwell on the enforceability of such waivers. See, e.g., United States v. Grillo, No. 99-1514, 1999 WL 1456536, at *2 (3d Cir. July 13, 1999); United States v. Salvagno, 314 F. Supp. 2d 115, 119 (N.D.N.Y. 2004); United States v.
Page: EFTA00013318 →se approximation of the value of the assets that Ms. Maxwell held in her own name at the time of her arrest..
Page: EFTA00013321 →[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
roceedings, the overall uncertainty of the government's evidence"); United States v. Karni, 298 F. Supp. 2d 129, 133 (D.D.C. 2004); United States v. Grillo, No. 99-1514, 1999 WL 1456536, at *2 (3d Cir. July 13, 1999); see also United States v. Georgiou, No. 08-1220- M, 2008 WL 4306750, at *3 (E.D. Pa. S
11 floor of the house. 12 Q. Did you ever see Ms. Maxwell taking 13 pictures of the girls? 14 A. No, ma'
w her doing that where were 9 they, the girls? 10 A. The dining room, the library, the first 11 floor of the house. 12 Q. Did you ever see Ms. Maxwell taking 13 pictures of the girls? 14 A. No, ma'am. 15 Q. Did you ever see Mr. Epstein taking 16 pictures of the girls? 17 A. No, ma'am. 18 Q
All right. Do you know where he owns 17 homes? 18 A. Yes. 19 Q. Where? 20 MR. CRITTON: Form. 21 THE WITNESS: Paris, New York City, El 22 Grillo, Saint James Island -- I'm sorry, an 2.3 Island in the Caribbean, and a ranch in New 24 Mexico. 25 BY MR. EDWARDS: Page 421 1 Q. What's the
(242 TOT SAC On Time TM More Selma was proNtled by 0 Oelertard ant! or Ocksterstags omens The Mid arc or print was tokl in keep me ,kryeete coon GM 'S Olha (Phone 355•2526) Memel of any Menge ol actin Y. by! Bin) 0 Nts fReesenk n j &McGinn? Descriplion at Properly 0 Yes 0 No Drug ArmIty
ad been previously told by her friends from W eigh School, what did d the appointment. picked up and drove her to Palm Beach to a street called `Grillo Way". They drove to the end of the street and entered a large driveway. They entered the kitchen area of the house and met with Epstein. was intro
Entities connected to both Ghislaine Maxwell and Grillo

Jeffrey Epstein
PERSON
United States
LOCATION
George W. Bush
PERSON
Bill Clinton
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATION
Marc Rich
PERSON
Bradley Edwards
PERSON
Julie K. Brown
PERSONFBI
ORGANIZATION
Joe Biden
PERSON
Vicky Ward
PERSON
Prince Charles
PERSON
Samantha Power
PERSON
Michael Jackson
PERSON
John F. Kennedy
PERSON
Jean-Luc Brunel
PERSON
Alfredo Rodriguez
PERSON
United Kingdom
LOCATION
Bloomberg L.P.
ORGANIZATION