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517 KB

Extraction Summary

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People
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Organizations
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Locations
3
Events
1
Relationships
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Quotes

Document Information

Type: Legal document
File Size: 517 KB
Summary

This legal document argues that Ms. Maxwell is not a flight risk and should be granted bail. The argument centers on her high public profile, which would make fleeing difficult, and her willingness to sign irrevocable waivers of extradition for both the United Kingdom and France. The document cites the case of United States v. Cirillo as a precedent for using such waivers as a condition for release.

People (2)

Name Role Context
Ms. Maxwell Defendant
The central figure of the document, whose bail conditions and flight risk are being discussed.
Cirillo Defendant
Mentioned as the defendant in a cited legal case, United States v. Cirillo.

Organizations (3)

Name Type Context
Court Government agency
The judicial body being addressed in the legal argument.
global press corps Media
Mentioned as a group that would relentlessly monitor Ms. Maxwell if she were granted bail.
3d Cir. Government agency
The United States Court of Appeals for the Third Circuit, which ruled on the cited case United States v. Cirillo.

Timeline (3 events)

1999-07-13
The 3rd Circuit Court of Appeals issued a ruling in the case of United States v. Cirillo.
3d Cir.
Discussion of Ms. Maxwell's potential bail hearing and the conditions that would apply.
The document mentions Ms. Maxwell's arrest as a point in time after which her circumstances changed.

Locations (3)

Location Context
A country where Ms. Maxwell will execute an irrevocable waiver of her right to contest extradition.
A country where Ms. Maxwell will execute an irrevocable waiver of her right to contest extradition.
The country from which an extradition request would be made if Ms. Maxwell were to flee.

Relationships (1)

Ms. Maxwell Legal
The document is a legal argument concerning Ms. Maxwell's status as a defendant and her potential for being granted bail by the Court.

Key Quotes (1)

"irrevocable waiver of extradition"
Source
— United States v. Cirillo case document (Quoted as a condition of release required of a foreign citizen in a previous legal case, used here as precedent.)
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Quote #1

Full Extracted Text

Complete text extracted from the document (2,151 characters)

Case: 20-6800-cr Document 392 Filed 06/25/2021 Page 32 of 1045
country. (Dkt. 18 at 12-14, Tr. 52-53). It is even more unfounded in light of the daily avalanche of media coverage of Ms. Maxwell. She is now one of the most recognizable and infamous people in the world. She is being pursued relentlessly by the press, which would no doubt be camped out by her front door every day if she were granted bail. The notion that Ms. Maxwell could somehow flee to a foreign country during a worldwide pandemic (presumably, by plane), while being supervised and monitored 24 hours a day and with the eyes of the global press corps on her every minute, without being caught, is absurd.
To the extent the Court is concerned that her calculus may have changed since her arrest because the threat of prosecution has now crystallized into concrete charges (Tr. 85-86), Ms. Maxwell has addressed that concern head-on—she will execute irrevocable waivers of her right to contest extradition in both the United Kingdom and France. (Ex. T). These waivers demonstrate Ms. Maxwell’s firm commitment to remain in this country to face the charges against her. Moreover, as discussed more fully in the attached expert reports, because of these waivers and other factors, it is highly unlikely that Ms. Maxwell would be able to successfully resist an extradition request from the United States to either country, in the extremely unlikely event she were to violate her bail conditions. (Exs. U-V). Moreover, any extradition proceedings in either country would be resolved promptly. (Id.).
Courts have addressed concerns about a defendant’s ties to a foreign state that enforces extradition waivers by requiring the defendant to execute such a waiver as a condition of release—including in cases where the defendants, unlike Ms. Maxwell, were not U.S. citizens. See, e.g., United States v. Cirillo, No. 99-1514, 1999 WL 1456536, at *2 (3d Cir. July 13, 1999) (vacating district court’s detention order and reinstating magistrate’s release order, which required foreign citizen and resident to sign an “irrevocable waiver of extradition” as a condition
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DOJ-OGR-00020046

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