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Extraction Summary
3
People
3
Organizations
3
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal filing (defense reply memorandum regarding bail/detention)
File Size:
772 KB
Summary
This page from a legal filing (Document 102) outlines arguments by Ghislaine Maxwell's defense team refuting the government's claim that she is a flight risk. The defense argues that her use of a trust and pseudonym to buy a home was for protection against harassment, not to hide, and emphasizes her willingness to waive extradition rights to France and the UK. It also addresses conflicting expert opinions regarding whether France would extradite her, contrasting expert William Julié's report with a general letter from the French Ministry of Justice.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the legal arguments regarding flight risk, purchase of a home, and extradition waivers.
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| William Julié | Expert Witness |
Provided an expert report stating it is 'highly unlikely' France would refuse to extradite Maxwell.
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| Real Estate Broker | Witness/Participant |
Unnamed individual to whom Maxwell provided a pseudonym when purchasing a home.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Government |
Arguing that Maxwell is a flight risk and her extradition waiver is meaningless.
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| Defense |
Arguing Maxwell's actions were for safety, not flight, and that she intends to face charges.
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| French Ministry of Justice (MOJ) |
Provided a letter stating the French Code of Criminal Procedure prohibits extradition of nationals.
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Timeline (2 events)
2020-12-28
Filing of Document 102 (Defense Reply Memorandum)
US District Court
Defense Team
Court
Prior to arrest
Locations (3)
| Location | Context |
|---|---|
|
Country of potential extradition/refuge; noted as prohibiting extradition of nationals.
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Country of potential extradition/refuge.
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referred to as 'the country' or 'this country' where Maxwell remained to defend her case.
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Relationships (2)
Reference to 'William Julié’s expert report' supporting Maxwell's defense.
Discussion of extradition rights and French laws prohibiting extradition of nationals.
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
"these steps were borne out of necessity to protect Ms. Maxwell and her family from harassment and physical threats."Source
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Quote #2
"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"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 (2,261 characters)
Case 1:20-cr-00330-AJN Document 102 Filed 12/28/20 Page 6 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.
D. Refusal of Extradition from France or the United Kingdom Is Highly 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.
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
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