DOJ-OGR-00001128.jpg
517 KB
Extraction Summary
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People
3
Organizations
3
Locations
3
Events
1
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
517 KB
Summary
This legal document, filed on December 14, 2020, argues that Ms. Maxwell is not a flight risk due to her extreme recognizability and the constant media scrutiny she faces. To further assure the Court of her intent to face charges, she offers to sign irrevocable waivers of her right to contest extradition in both the United Kingdom and France. The filing cites the 1999 case 'United States v. Cirillo' as a legal precedent for using such waivers as a condition for release.
People (2)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
The subject of the legal filing, arguing she is not a flight risk and is willing to sign extradition waivers.
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| Cirillo | Defendant |
Mentioned in the case citation 'United States v. Cirillo' as a precedent for requiring an extradition waiver.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| Court | government agency |
The judicial body being addressed in the legal argument.
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| global press corps | media |
Described as a group that would constantly monitor Ms. Maxwell if she were released on bail.
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| United States | government agency |
Mentioned as the country from which an extradition request would originate and as the plaintiff in the cited case 'Un...
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Timeline (3 events)
An argument is made that Ms. Maxwell is not a flight risk due to her high public profile and the constant media attention she receives.
Ms. Maxwell offers to execute irrevocable waivers of her right to contest extradition in the United Kingdom and France to demonstrate her commitment to remain in the country.
Locations (3)
| Location | Context |
|---|---|
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A country where Ms. Maxwell offers to waive her right to contest extradition.
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A country where Ms. Maxwell offers to waive her right to contest extradition.
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The country where Ms. Maxwell is facing charges and from which an extradition request would be made.
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Relationships (1)
The document is a legal argument presented to the Court on behalf of Ms. Maxwell, addressing the Court's concerns about her being a flight risk.
Key Quotes (1)
"irrevocable waiver of extradition"Source
— Court (in United States v. Cirillo)
(Quoted from a 1999 court case as a condition of release for a foreign citizen, used as precedent in the current argument.)
DOJ-OGR-00001128.jpg
Quote #1
Full Extracted Text
Complete text extracted from the document (2,151 characters)
Case 20-cr-00330-AJN Document 192 Filed 12/14/20 Page 31 of 45
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-00001128
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