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

u 6443111 JBE2 1 F I i t 8.255B3Reg EFISSeat 35 56 TABLE OF AUTHORITIES Jackson v. Goon!, 664 F. Supp. 2d 307 (S.D.N.Y. 2009) 27 United States v. Abdullahu, 488 F. Supp. 2d 433 (D.N.J. 2007) 19 United States v. Bank!, 10 Cr. 008 (JFK), Dkt. 7 (S.D.N.Y. Jan. 21, 2010), aff'd, 369 F. App'x 152 (2d Cir. 2

[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

al. See, e.g., United States v. Namer, 238 F.3d 425, 2000 WL 1872012, at •2 (6th Cir. Dec. 12, 2000); Chins, 2013 WL 3802012 at *2; United States v. Abdullahu, 488 F. Supp. 2d 433, 443 (D.N.J. 2007) ("The inability to extradite defendant should he flee weighs in favor of detention."). Beyond being imposs

[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

of Confinement 29 CONCLUSION 33 EFTA00103381 TABLE OF AUTHORITIES Jackson v. Goon!, 664 F. Supp. 2d 307 (S.D.N.Y. 2009) 27 United States v. Abdullahu, 488 F. Supp. 2d 433 (D.N.J. 2007) 19 United States v. Banki, 10 Cr. 008 (JFK), Dkt. 7 (S.D.N.Y. Jan. 21, 2010), aff'd, 369 F. App'x 152 (2d Cir. 2