DOJ-OGR-00002005.jpg
716 KB
Extraction Summary
7
People
3
Organizations
5
Locations
2
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal filing (defense memorandum regarding bail/release conditions)
File Size:
716 KB
Summary
This page is from a legal filing (Document 97) dated December 14, 2020, in the case of United States v. Ghislaine Maxwell. The defense argues that Maxwell should be granted bail conditions involving an extradition waiver, citing legal precedents (Salvagno, Karni, Chen, Khashoggi) where such waivers were accepted as assurances against flight. The document states Maxwell has obtained expert reports from French and UK experts (specifically David Perry regarding the UK) concluding that she would be unable to resist extradition back to the US if she fled to those countries after signing a waiver.
People (7)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
Subject of the bail application; obtained expert reports regarding extradition waivers.
|
| David Perry | Expert Witness / U.K. Barrister |
Provided a report ('Perry Rep.') on UK extradition law; described as a preeminent practitioner.
|
| Judge Keenan | Judge |
Cited in case precedent United States v. Khashoggi regarding extradition waivers.
|
| Salvagno | Defendant (Case Citation) |
Cited in United States v. Salvagno.
|
| Karni | Defendant (Case Citation) |
Cited in United States v. Karni.
|
| Chen | Defendant (Case Citation) |
Cited in United States v. Chen.
|
| Khashoggi | Defendant (Case Citation) |
Cited in United States v. Khashoggi.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| United States |
The entity seeking extradition in potential scenarios; the opposing party in the cited cases.
|
|
| Clerk of the Court |
Entity where waivers are filed in cited cases.
|
|
| Department of Justice (DOJ) |
Identified via Bates stamp 'DOJ-OGR-00002005'.
|
Timeline (2 events)
2020-12-14
Document 97 filed in Case 1:20-cr-00330-AJN
Court
Unknown
Ms. Maxwell obtained expert reports on extradition law
United Kingdom / France
Locations (5)
| Location | Context |
|---|---|
|
Potential location for flight; jurisdiction of expert David Perry.
|
|
|
Potential location for flight; jurisdiction for which an expert report was obtained.
|
|
|
Jurisdiction seeking potential extradition.
|
|
|
Mentioned in case citation United States v. Karni.
|
|
|
Mentioned in case citation United States v. Karni.
|
Relationships (1)
Ms. Maxwell has obtained the accompanying reports... submitted herewith is a report from David Perry
Key Quotes (3)
"Ms. Maxwell has obtained the accompanying reports of experts in United Kingdom and French extradition law, who have analyzed the likelihood that Ms. Maxwell, in the event she were to flee to the United Kingdom or France, would be able to resist extradition to the United States after having executed a waiver of her right to do so."Source
DOJ-OGR-00002005.jpg
Quote #1
"Both have concluded that it is highly unlikely that she would be able to resist extradition successfully."Source
DOJ-OGR-00002005.jpg
Quote #2
"Mr. Perry has acted on behalf of many overseas governments in extradition proceedings"Source
DOJ-OGR-00002005.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,084 characters)
Case 1:20-cr-00330-AJN Document 97 Filed 12/14/20 Page 33 of 45
of release); United States v. Salvagno, 314 F. Supp. 2d 115, 119 (N.D.N.Y. 2004) (ordering each
of two defendants to “execute and file with the Clerk of the Court a waiver of extradition
applicable to any nation or foreign territory in which he may be found as a condition of his
continued release”); United States v. Karni, 298 F. Supp. 2d 129, 132-33 (D.D.C. 2004)
(requiring Israeli citizen who lived in South Africa and had “no ties to the United States” to sign
waiver of rights not to be extradited under Israeli and South African extradition treaties with
United States); United States v. Chen, 820 F. Supp. 1205, 1212 (N.D. Cal. 1992) (ordering as a
condition of release that defendants “execute waivers of challenges to extradition from any
nation where they may be found”). Moreover, a defendant’s waiver of the right to appeal an
extradition order has been recognized as an indication of the defendant’s intent not to flee. See,
e.g., United States v. Khashoggi, 717 F. Supp. 1048, 1052 (S.D.N.Y. 1989) (Judge Keenan found
defendant’s extradition appeal waiver “manifests an intention to remain here and face the
charges against him”).
of two defendants to “execute and file with the Clerk of the Court a waiver of extradition
applicable to any nation or foreign territory in which he may be found as a condition of his
continued release”); United States v. Karni, 298 F. Supp. 2d 129, 132-33 (D.D.C. 2004)
(requiring Israeli citizen who lived in South Africa and had “no ties to the United States” to sign
waiver of rights not to be extradited under Israeli and South African extradition treaties with
United States); United States v. Chen, 820 F. Supp. 1205, 1212 (N.D. Cal. 1992) (ordering as a
condition of release that defendants “execute waivers of challenges to extradition from any
nation where they may be found”). Moreover, a defendant’s waiver of the right to appeal an
extradition order has been recognized as an indication of the defendant’s intent not to flee. See,
e.g., United States v. Khashoggi, 717 F. Supp. 1048, 1052 (S.D.N.Y. 1989) (Judge Keenan found
defendant’s extradition appeal waiver “manifests an intention to remain here and face the
charges against him”).
In response to the government’s assertions, Ms. Maxwell has obtained the accompanying
reports of experts in United Kingdom and French extradition law, who have analyzed the
likelihood that Ms. Maxwell, in the event she were to flee to the United Kingdom or France,
would be able to resist extradition to the United States after having executed a waiver of her right
to do so. Both have concluded that it is highly unlikely that she would be able to resist
extradition successfully.
reports of experts in United Kingdom and French extradition law, who have analyzed the
likelihood that Ms. Maxwell, in the event she were to flee to the United Kingdom or France,
would be able to resist extradition to the United States after having executed a waiver of her right
to do so. Both have concluded that it is highly unlikely that she would be able to resist
extradition successfully.
United Kingdom. With respect to the United Kingdom, submitted herewith is a report
from David Perry (“Perry Rep.”), a U.K. barrister who is widely considered one of the United
Kingdom’s preeminent extradition practitioners. (Perry Rep. Annex B ¶ 2.1) (attached as Exhibit
U). Mr. Perry has acted on behalf of many overseas governments in extradition proceedings; has
from David Perry (“Perry Rep.”), a U.K. barrister who is widely considered one of the United
Kingdom’s preeminent extradition practitioners. (Perry Rep. Annex B ¶ 2.1) (attached as Exhibit
U). Mr. Perry has acted on behalf of many overseas governments in extradition proceedings; has
27
DOJ-OGR-00002005
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document