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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
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
ant accepted responsibility is entitled to great deference, and we will reverse it only if it is so clearly erroneous as to be without foundation. United Slates v. Lit- tle Hawk, 449 F.3d 837, 839 (8th Cir.2006). 16] In certain "rare situations," a de- fendant may clearly demonstrate accep- tance of responsi
t conduct outside of the United States for the purpose of producing a visual depiction of such conduct and transporting that visual depiction into the United States, in violation of 18 U.S.C. § 2251(cX2XB) and (e) (Count Three). Deverso's appeal presents three issues for review, two of which present novel ques
he presumption does in fact apply. As a matter of law, the Indict- ment in this case, standing alone, suffices to establish probable... 8. H U.S.'. Abdullahu, 488 F.Supp.2d 433, 2007 WL 1556837, D.N.J., May 24, 2007(No. 07-2050 (IS).) ...Attorney , Camden, NJ, for United States of America. OPINION DENYIN
turns," including the "suppression of video evidence, the indeterminate stay of proceedings, 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 Uni
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
turns," including the "suppression of video evidence, the indeterminate stay of proceedings, 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. Cirillo, No. 99-1514, 1999 WL 1456536, at *2 (3d Cir. July 13, 1999); see also Un
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
Entities connected to both United States and Abdullahu

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
John F. Kennedy
PERSONFBI
ORGANIZATION
Samantha Power
PERSONSouthern District
LOCATION
Southern District of New York
ORGANIZATION
Michael Cohen
PERSON
Michael Jackson
PERSON
United Kingdom
LOCATIONSecond Circuit
ORGANIZATION
Glenn Dubin
PERSON
Audrey Strauss
PERSONMorrison
PERSON
Rahm Emanuel
PERSONPeterson
PERSONKarni
PERSONBoustani
PERSON