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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
d States v. Epstein, 425 F. Supp. 3d 306 (S.D.N.Y. 2019) 15, 29 United States v. Esposito, 309 F. Supp. 3d 24 (S.D.N.Y. 2018) 27 United States v. Georgiou, No. 08-1220-M, 2008 WL 4306750 (E.D. Pa. Sept. 22, 2008) 15 United States v. Karni, 298 F. Supp. 2d 129 (D.D.C. 2004) 15 United States v. Kazeem
[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
F. Supp. 2d 129, 133 (D.D.C. 2004); United States v. Cirillo, 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. Sept. 22, 2008) (distinguishing Cirillo on the facts and noting that "defense counsel concedes tha
[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
d States v. Epstein, 425 F. Supp. 3d 306 (S.D.N.Y. 2019) 15, 29 United States v. Esposito, 309 F. Supp. 3d 24 (S.D.N.Y. 2018) 27 United States v. Georgiou, No. 08-1220-M, 2008 WL 4306750 (E.D. Pa. Sept. 22, 2008) 15 United States v. Karni, 298 F. Supp. 2d 129 (D.D.C. 2004) 15 United States v. Kazeem
Entities connected to both Ghislaine Maxwell and Georgiou

Jeffrey Epstein
PERSONSouthern District
LOCATION
United States
LOCATION
Michael Cohen
PERSON
Department of Justice
ORGANIZATIONFBI
ORGANIZATION
Audrey Strauss
PERSON
Michael Jackson
PERSON
John F. Kennedy
PERSON
United Kingdom
LOCATIONSecond Circuit
ORGANIZATION
Southern District of New York
ORGANIZATION
Glenn Dubin
PERSON
Stanton
PERSONMorrison
PERSON
Rahm Emanuel
PERSON
Bernie Madoff
PERSONPeterson
PERSONKarni
PERSONBoustani
PERSON