{
  "document_metadata": {
    "page_number": "11",
    "document_number": "106",
    "date": "12/30/20",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 106 Filed 12/30/20 Page 11 of 22\n\nCOVID-19 related travel restrictions. Id. at 83:21–83:25. The Court also observed that the Defendant had family and personal connections to the United States but concluded that the absence of any dependents, significant family ties, or employment in the United States also supported the conclusion that flight would not pose an insurmountable burden for her. Id. at 84:4–84:9. While the Defendant’s renewed motion for bail addresses some of these factors, it does not alter the Court’s conclusion.\n\nThe first few considerations remain relatively unchanged. The Defendant continues to have substantial international ties and multiple foreign citizenships, and she continues to have familial and personal connections abroad. None of the evidence presented in support of the present motion fundamentally alters those conclusions. To address the Court’s concern that the Defendant’s French citizenship presented the opportunity that she could flee to France and that she would be able to resist extradition on that basis, see Tr. at 83:18–83:20, the Defendant now offers to waive her right to extradition from both the United Kingdom and France, along with expert opinions reports claiming that such waivers would likely make it possible to resist an extradition request from the United States to either country. See Def. Mot., Exs. T, U, V. As the Government points out in its brief, however, the legal weight of the waivers is, at best, contested. The French Ministry of Justice, for instance, indicated in a letter submitted in conjunction to the Government’s opposition that the French Code of Criminal Procedure “absolutely prohibits” the extradition of a French national. See Gov’t Opp’n, Ex. B. And while the Defendant’s own expert attempts to rebut the Ministry of Justice’s letter, see Def. Reply, Ex. A, even the Defendant’s own experts use probabilistic, rather than absolute, language, leaving open the possibility that extradition would be blocked. See, e.g., Def. Mot., Ex. U at 2 (“On the basis of the information currently known, it is highly unlikely that Ghislaine Maxwell would be able\n\n11\n\nDOJ-OGR-00002243",
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      "content": "Case 1:20-cr-00330-AJN Document 106 Filed 12/30/20 Page 11 of 22",
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    {
      "type": "printed",
      "content": "COVID-19 related travel restrictions. Id. at 83:21–83:25. The Court also observed that the Defendant had family and personal connections to the United States but concluded that the absence of any dependents, significant family ties, or employment in the United States also supported the conclusion that flight would not pose an insurmountable burden for her. Id. at 84:4–84:9. While the Defendant’s renewed motion for bail addresses some of these factors, it does not alter the Court’s conclusion.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The first few considerations remain relatively unchanged. The Defendant continues to have substantial international ties and multiple foreign citizenships, and she continues to have familial and personal connections abroad. None of the evidence presented in support of the present motion fundamentally alters those conclusions. To address the Court’s concern that the Defendant’s French citizenship presented the opportunity that she could flee to France and that she would be able to resist extradition on that basis, see Tr. at 83:18–83:20, the Defendant now offers to waive her right to extradition from both the United Kingdom and France, along with expert opinions reports claiming that such waivers would likely make it possible to resist an extradition request from the United States to either country. See Def. Mot., Exs. T, U, V. As the Government points out in its brief, however, the legal weight of the waivers is, at best, contested. The French Ministry of Justice, for instance, indicated in a letter submitted in conjunction to the Government’s opposition that the French Code of Criminal Procedure “absolutely prohibits” the extradition of a French national. See Gov’t Opp’n, Ex. B. And while the Defendant’s own expert attempts to rebut the Ministry of Justice’s letter, see Def. Reply, Ex. A, even the Defendant’s own experts use probabilistic, rather than absolute, language, leaving open the possibility that extradition would be blocked. See, e.g., Def. Mot., Ex. U at 2 (“On the basis of the information currently known, it is highly unlikely that Ghislaine Maxwell would be able",
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    {
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      "content": "DOJ-OGR-00002243",
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  ],
  "entities": {
    "people": [
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "French Ministry of Justice"
    ],
    "locations": [
      "United States",
      "France",
      "United Kingdom"
    ],
    "dates": [
      "12/30/20"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 106",
      "DOJ-OGR-00002243"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ghislaine Maxwell. The text discusses the defendant's bail and extradition. The document is well-formatted and legible."
}