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732 KB
Extraction Summary
2
People
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Organizations
3
Locations
2
Events
1
Relationships
4
Quotes
Document Information
Type:
Court filing / legal memorandum (defense motion for bail)
File Size:
732 KB
Summary
This document is page 32 of a defense filing (Document 97) dated December 14, 2020, arguing for Ghislaine Maxwell's release on bail. The text argues that Maxwell is not a flight risk due to intense media scrutiny, the global pandemic, and her willingness to sign irrevocable extradition waivers for the UK and France. It cites legal precedent (US v. Cirillo) supporting the use of extradition waivers as a condition for release.
People (2)
| Name | Role | Context |
|---|---|---|
| Ms. Maxwell | Defendant |
Subject of the bail hearing; described as one of the most recognizable and infamous people in the world.
|
| Cirillo | Defendant in cited case |
Cited in United States v. Cirillo precedent regarding extradition waivers.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| United States District Court |
Implied by case number and context of filing.
|
|
| Global press corps |
Described as pursuing Maxwell relentlessly.
|
|
| DOJ |
Department of Justice (indicated in Bates stamp DOJ-OGR-00002004).
|
Locations (3)
| Location | Context |
|---|---|
|
Country where Maxwell is offering to waive extradition rights.
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Country where Maxwell is offering to waive extradition rights.
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Current location where she faces charges.
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Relationships (1)
She is being pursued relentlessly by the press
Key Quotes (4)
"She is now one of the most recognizable and infamous people in the world."Source
DOJ-OGR-00002004.jpg
Quote #1
"The notion that Ms. Maxwell could somehow flee to a foreign country during a worldwide pandemic... is absurd."Source
DOJ-OGR-00002004.jpg
Quote #2
"she will execute irrevocable waivers of her right to contest extradition in both the United Kingdom and France."Source
DOJ-OGR-00002004.jpg
Quote #3
"Ms. Maxwell has addressed that concern head-on"Source
DOJ-OGR-00002004.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (2,152 characters)
Case 1:20-cr-00330-AJN Document 97 Filed 12/14/20 Page 32 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.
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.).
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
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-00002004
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