DOJ-OGR-00001129.jpg
508 KB
Extraction Summary
7
People
2
Organizations
5
Locations
1
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal filing (defense memorandum/motion for bail)
File Size:
508 KB
Summary
This document is page 33 of a legal filing (dated Dec 14, 2020) in the case of United States v. Ghislaine Maxwell. It argues that Maxwell is not a flight risk because she has executed waivers of extradition and obtained expert reports (specifically from U.K. barrister David Perry) concluding she could not successfully resist extradition from the U.K. or France. The text cites various legal precedents (Salvagno, Karni, Chen, Khashoggi) to support the validity of extradition waivers as conditions of release.
People (7)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the legal argument regarding flight risk and extradition waivers.
|
| David Perry | Expert Witness / U.K. Barrister |
Provided a report regarding U.K. extradition law to support Maxwell's defense.
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| Judge Keenan | Judge |
Cited in case law (United States v. Khashoggi) regarding extradition appeal waivers.
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| Salvagno | Defendant (Case Law) |
Cited in United States v. Salvagno.
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| Karni | Defendant (Case Law) |
Cited in United States v. Karni.
|
| Chen | Defendant (Case Law) |
Cited in United States v. Chen.
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| Khashoggi | Defendant (Case Law) |
Cited in United States v. Khashoggi.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| United States District Court |
Implied by case citations (N.D.N.Y., D.D.C., N.D. Cal., S.D.N.Y.).
|
|
| Department of Justice (DOJ) |
Source of the document (DOJ-OGR stamp).
|
Timeline (1 events)
2020-12-14
Locations (5)
| Location | Context |
|---|---|
|
Potential flight location discussed; jurisdiction for expert report.
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Potential flight location discussed.
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Jurisdiction seeking extradition.
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Mentioned in case law (United States v. Karni).
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Mentioned in case law (United States v. Karni).
|
Relationships (1)
Maxwell obtained report from Perry regarding extradition.
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"Source
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Quote #1
"Both have concluded that it is highly unlikely that she would be able to resist extradition successfully."Source
DOJ-OGR-00001129.jpg
Quote #2
"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."Source
DOJ-OGR-00001129.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,084 characters)
Case 1:20-cr-00330-AJN Document 127 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
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DOJ-OGR-00001129
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