Epstein Secrets

ed. 18 U.S.C. § 3142(0. The Court is not required to do so if it determines that any new information would not have a material bearing on the issue. See United States v. Raniere, No. 18-CR-204I (NGG) (VMS), 2018 WL 6344202, at *2 n.7 (E.D.N.Y. Dec. 5, 2018) (noting that "[als the court has already held one detent

may also revisit its own decision pursuant to its inherent authority, even when the circumstances do not match § 3142(0's statutory text. See, e.g., United States v. Rowe, No. 02-CR-756 (LMM), 2003 WL 21196846, at *1 (S.D.N.Y. May 21, 2003) (noting that "a release order may be reconsidered even where the evide

s on the correct interpretation of French law. The Government relies on the position of the head of the International Criminal Assistance Bureau of the French Ministry of Justice, who argues that "the fact that the wanted individual is a French national constitutes an insuperable obstacle to his/her removal," and that lais lo

lly certain that bail would be refused in an extradition case in circumstances where the requested person had absconded from criminal proceedings in the United States prior to trial and in breach of bail; and (c) on the basis of the information currently known, it is highly unlikely' that Ghislaine Maxwell would b

iiiiest:20-?gOODBOAMt Itibtfinfldift1100221, $0611293180p2Pigel 351 4 Article 3 of the Bilateral Extradition Treaty signed on April 23, 1996 between the United States of America and France stipulates that "The requested State is not bound to grant the extradition of any of its nationals, but the Executive Power of the United

s "highly unlikely" that the French government would refuse to extradite Ms. Maxwell (Def. Mem., Ex. V at 2), the government attaches a letter from the French Ministry of Justice ("MOJ") that references neither Mr. Julie's report nor Ms. Maxwell, but states generally that the French Code of Criminal Procedure "absolutely pro

in France, please ensure that this mutual legal assistance request is NOT placed in the French criminal dossier without the express authorization of the United States; instead, we ask that this request for assistance be placed in a separate mutual legal assistance dossier. If this request cannot be executed withou

secution of Maxwell. The U.S. authorities learned of certain of these records from the July 8, 2020 request for international legal assistance from the French Ministry of Justice. In particular, the U.S. authorities request that an appropriate custodian of official records produce true and correct copies of the following doc

in France, please ensure that this mutual legal assistance request is NOT placed in the French criminal dossier without the express authorization of the United States; instead, we ask that this request for assistance be placed in a separate mutual legal assistance dossier. If this request cannot be executed withou

secution of Maxwell. The U.S. authorities learned of certain of these records from the July 8, 2020 request for international legal assistance from the French Ministry of Justice. In particular, the U.S. authorities request that an appropriate custodian of official records produce true and correct copies of the following doc

in France, please ensure that this mutual legal assistance request is NOT placed in the French criminal dossier without the express authorization of the United States; instead, we ask that this request for assistance be placed in a separate mutual legal assistance dossier. If this request cannot be executed withou

secution of Maxwell. The U.S. authorities learned of certain of these records from the July 8, 2020 request for international legal assistance from the French Ministry of Justice. In particular, the U.S. authorities request that an appropriate custodian of official records produce true and correct copies of the following doc

r country. See Def. Mot., Exs. T, U, V. As the Government points out in its brief, however, the legal weight of the waivers is, at best, contested. The French Ministry of Justice, for instance, indicated in a letter submitted in conjunction to the Government's opposition that the French Code of Criminal Procedure "absolutely

y had enjoyed. Def. Mot. at 11; see also Def. Mot, Ex. A 1114-5. Other letters similarly highlight that the Defendant's family and affective ties in the United States are stronger than was originally presented to the Court in the initial bail hearing. These letters substantiate the Defendant's claim that she has i

s "highly unlikely" that the French government would refuse to extradite Ms. Maxwell (Def. Mem., Ex. V at 2), the government attaches a letter from the French Ministry of Justice ("MOP') that references neither Mr. Julie's report nor Ms. Maxwell, but states generally that the French Code of Criminal Procedure "absolutely pro

U.S. citizen—provides no precedent as to how a French court would rule on an extradition request regarding Ms. Maxwell because, as Mr. Julie notes, the United States did not challenge the refusal in the French courts. (/d. at 2-3). Nor does it undermine Mr. Julia's opinion that, in the unusual circumstance where

s "highly unlikely" that the French government would refuse to extradite Ms. Maxwell (Def. Mem., Ex. V at 2), the government attaches a letter from the French Ministry of Justice ("MOJ") that references neither Mr. Julie's report nor Ms. Maxwell, but states generally that the French Code of Criminal Procedure "absolutely pro

U.S. citizen—provides no precedent as to how a French court would rule on an extradition request regarding Ms. Maxwell because, as Mr. Julie notes, the United States did not challenge the refusal in the French courts. (Id. at 2-3). Nor does it undermine Mr. Julie's opinion that, in the unusual circumstance where

s "highly unlikely" that the French government would refuse to extradite Ms. Maxwell (Def. Mem., Ex. V at 2), the government attaches a letter from the French Ministry of Justice ("MOJ") that references neither Mr. Julie's report nor Ms. Maxwell, but states generally that the French Code of Criminal Procedure "absolutely pro

U.S. citizen—provides no precedent as to how a French court would rule on an extradition request regarding Ms. Maxwell because, as Mr. Julie notes, the United States did not challenge the refusal in the French courts. (Id. at 2-3). Nor does it undermine Mr. Julie's opinion that, in the unusual circumstance where

ited States of America and the European Union s ivied in Washington on 25 June 2003, and the Instalment Amending the Treaty of 23 Apnl 1996 between the United States of Amok a and France signed in the Hague on 30 September 2004. 2 51, RUE AmvERE • 75017 RARis tee. 01 88 33 51 80 — FAX. 01 88 33 51 81 wjeJwjavocats.com •

e de droll penal et de procedure penale Extradition Pa. - Conditions de fond de l'estradition Delphine Brach-Thiel-October 2t I 8„f59). 18. Third, the French Ministry of Justice's interpretation is contradicted by precedents and case law 19. The French Ministry of Justice's interpretation finds no support in case law, as no