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509 KB

Extraction Summary

7
People
1
Organizations
8
Locations
4
Events
1
Relationships
4
Quotes

Document Information

Type: Legal document
File Size: 509 KB
Summary

This legal document, part of a court filing, argues on behalf of Ms. Maxwell by citing several past U.S. court cases where defendants waived extradition rights to demonstrate they were not a flight risk. It then introduces expert reports, specifically one from U.K. barrister David Perry, which conclude it is highly unlikely Ms. Maxwell could successfully resist extradition from the U.K. or France back to the United States, further supporting the argument that she is not a flight risk.

People (7)

Name Role Context
Salvagno Defendant
Mentioned as a defendant in the cited case United States v. Salvagno.
Karni Defendant
Mentioned as a defendant in the cited case United States v. Karni, described as an Israeli citizen who lived in South...
Chen Defendant
Mentioned as a defendant in the cited case United States v. Chen.
Khashoggi Defendant
Mentioned as a defendant in the cited case United States v. Khashoggi.
Judge Keenan Judge
Mentioned as the judge who made a finding in the United States v. Khashoggi case.
Ms. Maxwell Subject of the legal proceeding
The individual for whom expert reports on extradition law have been obtained.
David Perry U.K. barrister
An expert in U.K. extradition law who provided a report regarding Ms. Maxwell's case. Referred to as "Perry Rep."

Organizations (1)

Name Type Context
Clerk of the Court government agency
Mentioned in the context of the United States v. Salvagno case, where defendants were ordered to file a waiver of ext...

Timeline (4 events)

1989
United States v. Khashoggi, 717 F. Supp. 1048, 1052 (S.D.N.Y. 1989)
S.D.N.Y.
1992
United States v. Chen, 820 F. Supp. 1205, 1212 (N.D. Cal. 1992)
N.D. Cal.
2004
United States v. Salvagno, 314 F. Supp. 2d 115, 119 (N.D.N.Y. 2004)
N.D.N.Y.
2004
United States v. Karni, 298 F. Supp. 2d 129, 132-33 (D.D.C. 2004)
D.D.C.

Locations (8)

Location Context
The court district for the United States v. Salvagno case (Northern District of New York).
The court district for the United States v. Karni case (District of Columbia).
The country where the defendant in United States v. Karni lived.
The country central to the extradition discussions and legal cases cited.
The court district for the United States v. Chen case (Northern District of California).
The court district for the United States v. Khashoggi case (Southern District of New York).
A country where Ms. Maxwell might potentially flee, and for which an expert report on extradition law was obtained.
A country where Ms. Maxwell might potentially flee, and for which an expert report on extradition law was obtained.

Relationships (1)

Ms. Maxwell Professional David Perry
Ms. Maxwell's side obtained a report from David Perry, a U.K. barrister, to serve as an expert on extradition law for her case.

Key Quotes (4)

"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"
Source
— Court in United States v. Salvagno (An order from the court in the Salvagno case, cited as precedent.)
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Quote #1
"no ties to the United States"
Source
— Unknown (A description of the defendant in the United States v. Karni case.)
DOJ-OGR-00020047.jpg
Quote #2
"execute waivers of challenges to extradition from any nation where they may be found"
Source
— Court in United States v. Chen (An order from the court in the Chen case, cited as precedent.)
DOJ-OGR-00020047.jpg
Quote #3
"manifests an intention to remain here and face the charges against him"
Source
— Judge Keenan (A finding by Judge Keenan in the United States v. Khashoggi case regarding the defendant's waiver of extradition appeal.)
DOJ-OGR-00020047.jpg
Quote #4

Full Extracted Text

Complete text extracted from the document (2,079 characters)

Case: 20-680-cr Document 39-2 Filed 06/25/20 Page 32 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”).
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.
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
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