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she would be able to resist extradition on that basis, see Tr. at 83:1843:20, the Defendant now offers to waive her right to extradition from both the United Kingdom and France, along with expert opinions reports claiming that such waivers would likely make it possible to resist an extradition request from the U
Page: EFTA00013317 →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
Page: EFTA00013317 →llenged by the requesting government before the French Conseil d'Etat, which is the French Supreme Court for administrative matters, as for example the United Kingdom and Hong Kong successfully challenged a decision from the French authorities not to extradite an individual whose extradition they had requested (Co
s citizens under French legislation. In accordance with this French constitutional rule, the administrative circular of 11 March 2004, published by the French Ministry of Justice, which aims at specifying how the then recently amended legal provisions regarding extradition should apply and be understood, states the following
g that France does not appear to extradite its own citizens. (Tr. 83). The defendant's supposed waiver of her extradition rights with respect to the United Kingdom should similarly be afforded no weight. Although an anticipatory waiver of extradition may be admissible in extradition proceedings in the United Ki
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
e Government's Assertion that Ms. Maxwell Is "Adept" at Hiding and Therefore a Flight Risk Is Specious 7 D. Refusal of Extradition from France or the United Kingdom Is Highly Unlikely 8 E. The Recent COVID Surge at MDC Further Justifies Bail 10 CONCLUSION 10 i EFTA00015978 --- PAGE BREAK --- TABLE OF
Page: EFTA00015978 →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
Page: EFTA00015988 →5 C. The Government's Assertion that Ms. Maxwell Is "Adept" at Hiding and Therefore a Flight Risk Is Specious 7 D. Extradition from France or the United Kingdom Is Highly Unlikely 8 E. The Recent COVID Surge at MDC Further Justifies Bail 10 CONCLUSION 10 i EFTA00016770 --- PAGE BREAK --- TABLE OF
Page: EFTA00016770 →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
Page: EFTA00016780 →s citizens under French legislation. In accordance with this French constitutional rule, the administrative circular of 11 March 2004, published by the French Ministry of Justice, which aims at specifying how the then recently amended legal provisions regarding extradition should apply and be understood, states the following
Page: EFTA00016785 →llenged by the requesting government before the French Conseil d'Etat, which is the French Supreme Court for administrative matters, as for example the United Kingdom and Hong Kong successfully challenged a decision from the French authorities not to extradite an individual whose extradition they had requested (Co
Page: EFTA00016786 →5 C. The Government's Assertion that Ms. Maxwell Is "Adept" at Hiding and Therefore a Flight Risk Is Specious 7 D. Extradition from France or the United Kingdom Is Highly Unlikely 8 E. The Recent COVID Surge at MDC Further Justifies Bail 10 CONCLUSION 10 EFTA00019292 --- PAGE BREAK --- TABLE OF AUT
Page: EFTA00019292 →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
Page: EFTA00019302 →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
Page: EFTA00031933 →PAGE BREAK --- WILLIAM JULIE AVOCAT A LA COUR - ATTORNEY AT LAW extradition and other removals", ECtHR 12 April 2012, Babar Ahmad and Others v. the United Kingdom, no. 24027/07, §168). 23. France has no difficulty with deporting individuals who have lost French nationality by application of Article 25 of the
Page: EFTA00031934 →Entities connected to both United Kingdom and the French Ministry of Justice

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
New York
LOCATION
Barack Obama
PERSONthe Southern District
LOCATION
Michael Cohen
PERSON
Denver
LOCATIONFBI
ORGANIZATION
Alfredo Rodriguez
PERSON
Southern District of New York
ORGANIZATION
Jean-Luc Brunel
PERSONJeffrey Pagliuca
PERSONCohen & Gresser LLP
ORGANIZATION
David Rodgers
PERSONSecond Circuit
ORGANIZATIONO'Brien
PERSONKarni
PERSONMorrison
PERSON
Mattis
PERSON