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772 KB
Extraction Summary
2
People
2
Organizations
3
Locations
1
Events
1
Relationships
4
Quotes
Document Information
Type:
Legal brief / memorandum (defense filing)
File Size:
772 KB
Summary
This document is page 8 of a legal memorandum filed by Ghislaine Maxwell's defense on December 28, 2020. It argues against the government's assertion that Maxwell is a flight risk, claiming her use of a trust and pseudonym to buy a home was for safety, not evasion. The defense also contends that Maxwell's waiver of extradition rights is significant and cites expert William Julié to counter claims that France would refuse to extradite her.
People (2)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the motion; defense argues she is not a flight risk and acted to protect her family.
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| William Julié | Expert Witness |
Authored an expert report stating it is highly unlikely the French government would refuse to extradite Maxwell.
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Organizations (2)
| Name | Type | Context |
|---|---|---|
| French Ministry of Justice |
Referred to as 'MOJ'; provided a letter stating the French Code of Criminal Procedure prohibits extradition of nation...
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| United States Government |
Referred to as 'The government'; arguing against Maxwell's release.
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Timeline (1 events)
2020-12-28
Filing of Defense Memorandum (Document 103-2)
US District Court
Defense Counsel
US Government
Locations (3)
| Location | Context |
|---|---|
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Country of potential extradition/refuge.
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Country of potential extradition/refuge.
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Implied as 'this country' where Maxwell remains to face charges.
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Relationships (1)
Defense utilizes Julié's expert report to argue extradition likelihood.
Key Quotes (4)
"The government suggests that purchasing a home using a trust and providing a pseudonym to a real estate broker are indicative of her willingness and ability to live in hiding"Source
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Quote #1
"Refusal of Extradition from France or the United Kingdom Is Highly Unlikely"Source
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Quote #2
"Ms. Maxwell’s willingness to do everything she can to eliminate her ability to refuse extradition... demonstrates her firm commitment to remain in this country"Source
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Quote #3
"French Code of Criminal Procedure 'absolutely prohibits' the extradition of a French national."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,253 characters)
Case 1:20-cr-00330-AJN Document 103-2 Filed 12/28/20 Page 16 of 15
(Gov. Mem. at 20). The government suggests that purchasing a home using a trust and providing
a pseudonym to a real estate broker are indicative of her willingness and ability to live in hiding
and somehow forecast Ms. Maxwell’s intention to flee. (Id.). These arguments are just further
evidence that the government will frame every fact about Ms. Maxwell in the worst possible
light. As the defense has already argued extensively in its initial brief, these steps were borne
out of necessity to protect Ms. Maxwell and her family from harassment and physical threats.
Moreover, they are not predictive of flight. There is simply no basis to conclude, based on the
measures that Ms. Maxwell was forced to take to protect herself and her family, that she would
then willingly abandon that family to become a fugitive from justice. To the contrary, she
remained in the country precisely to remain close to them and to defend her case.
a pseudonym to a real estate broker are indicative of her willingness and ability to live in hiding
and somehow forecast Ms. Maxwell’s intention to flee. (Id.). These arguments are just further
evidence that the government will frame every fact about Ms. Maxwell in the worst possible
light. As the defense has already argued extensively in its initial brief, these steps were borne
out of necessity to protect Ms. Maxwell and her family from harassment and physical threats.
Moreover, they are not predictive of flight. There is simply no basis to conclude, based on the
measures that Ms. Maxwell was forced to take to protect herself and her family, that she would
then willingly abandon that family to become a fugitive from justice. To the contrary, she
remained in the country precisely to remain close to them and to defend her case.
D. Refusal of Extradition from France or the United Kingdom Is Highly
Unlikely
Unlikely
The government dismisses Ms. Maxwell’s willingness to waive her extradition rights as
to France and the United Kingdom as “meaningless” because Ms. Maxwell cannot guarantee
with absolute certainty that either country will enforce the waiver. (Gov. Mem. at 14). The
government misses the point: Ms. Maxwell’s willingness to do everything she can to eliminate
her ability to refuse extradition to the fullest extent possible demonstrates her firm commitment
to remain in this country to face the charges against her and, as Ms. Maxwell’s French and U.K.
experts confirm, there is every reason to believe that both authorities would consider the waiver
as part of any extradition request.
to France and the United Kingdom as “meaningless” because Ms. Maxwell cannot guarantee
with absolute certainty that either country will enforce the waiver. (Gov. Mem. at 14). The
government misses the point: Ms. Maxwell’s willingness to do everything she can to eliminate
her ability to refuse extradition to the fullest extent possible demonstrates her firm commitment
to remain in this country to face the charges against her and, as Ms. Maxwell’s French and U.K.
experts confirm, there is every reason to believe that both authorities would consider the waiver
as part of any extradition request.
In an attempt to counter William Julié’s expert report stating it is “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. Julié’s report nor Ms. Maxwell, but states generally that the French Code of Criminal
Procedure “absolutely prohibits” the extradition of a French national. (Gov. Mem., Ex. B). But
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. Julié’s report nor Ms. Maxwell, but states generally that the French Code of Criminal
Procedure “absolutely prohibits” the extradition of a French national. (Gov. Mem., Ex. B). But
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