{
  "document_metadata": {
    "page_number": "13",
    "document_number": "171",
    "date": "03/23/21",
    "document_type": "memorandum",
    "has_handwriting": false,
    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 171 Filed 03/23/21 Page 13 of 18\n\nWILLIAM JULIÉ\nAVOCAT À LA COUR - ATTORNEY AT LAW\n\nMarch 14th 2021\n\nRe: Additional opinion on the extradition of nationals by the French government\n\n1. This memorandum was written pursuant to a request from Olivier Laude, a partner at the French firm Laude Esquicr Champey acting on behalf of Cohen & Gresser LLP as counsel for Ms Ghislaine Maxwell. The request was made in the context of ongoing bail proceedings involving Ms Maxwell in the United States of America (hereafter \"USA\"), where Ms Maxwell is being detained pre-trial on charges relating to her alleged role in sexual activities involving Jeffrey Epstein from 1994 to 1997.\n\n2. In a previous opinion, I have outlined why French authorities could decide to execute an extradition request against a French citizen under the Extradition Treaty between the USA and France, without violating any superior norm of French and international law.\n\n3. As I understand the defendant's French nationality continues to be regarded by the Court as a bar to her release pending trial, I am informed that the defendant is prepared to renounce French nationality under Article 23-4 of the French Civil Code, if the Court so requires.\n\n4. In a letter to the Department of Justice dated 9 March 2021, the Head of the International Criminal Assistance Bureau of the French Ministry of Justice, Mr Philippe Jaeglé, asserts that the loss of French nationality after the criminal act which the person is alleged to have committed does not affect the rule against the extradition of nationals, as nationality must be assessed at the time of commission of the offence and not at the time of the extradition request.\n\n5. This report was written to provide a counter opinion on this issue, in support of the proposition that the French government would be legally entitled to execute an extradition request against an individual who is no longer a French national.\n\n6. The Ministry of Justice's assertion must be regarded as incorrect for three reasons:\n\n(i) It is not supported by the letter of the law;\n\n51, RUE AMPÈRE - 75017 PARIS - TÉL. 01 88 33 51 80 - FAX. 01 88 33 51 81\nwj@wjavocats.com - www.wjavocats.com - PALAIS C1652\n\n1\n\nDOJ-OGR-00002793",
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      "content": "Case 1:20-cr-00330-PAE Document 171 Filed 03/23/21 Page 13 of 18",
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    {
      "type": "printed",
      "content": "WILLIAM JULIÉ\nAVOCAT À LA COUR - ATTORNEY AT LAW",
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    {
      "type": "printed",
      "content": "March 14th 2021",
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    {
      "type": "printed",
      "content": "Re: Additional opinion on the extradition of nationals by the French government",
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      "type": "printed",
      "content": "1. This memorandum was written pursuant to a request from Olivier Laude, a partner at the French firm Laude Esquicr Champey acting on behalf of Cohen & Gresser LLP as counsel for Ms Ghislaine Maxwell. The request was made in the context of ongoing bail proceedings involving Ms Maxwell in the United States of America (hereafter \"USA\"), where Ms Maxwell is being detained pre-trial on charges relating to her alleged role in sexual activities involving Jeffrey Epstein from 1994 to 1997.",
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    },
    {
      "type": "printed",
      "content": "2. In a previous opinion, I have outlined why French authorities could decide to execute an extradition request against a French citizen under the Extradition Treaty between the USA and France, without violating any superior norm of French and international law.",
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    },
    {
      "type": "printed",
      "content": "3. As I understand the defendant's French nationality continues to be regarded by the Court as a bar to her release pending trial, I am informed that the defendant is prepared to renounce French nationality under Article 23-4 of the French Civil Code, if the Court so requires.",
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    },
    {
      "type": "printed",
      "content": "4. In a letter to the Department of Justice dated 9 March 2021, the Head of the International Criminal Assistance Bureau of the French Ministry of Justice, Mr Philippe Jaeglé, asserts that the loss of French nationality after the criminal act which the person is alleged to have committed does not affect the rule against the extradition of nationals, as nationality must be assessed at the time of commission of the offence and not at the time of the extradition request.",
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    {
      "type": "printed",
      "content": "5. This report was written to provide a counter opinion on this issue, in support of the proposition that the French government would be legally entitled to execute an extradition request against an individual who is no longer a French national.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "6. The Ministry of Justice's assertion must be regarded as incorrect for three reasons:\n\n(i) It is not supported by the letter of the law;",
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    },
    {
      "type": "printed",
      "content": "51, RUE AMPÈRE - 75017 PARIS - TÉL. 01 88 33 51 80 - FAX. 01 88 33 51 81\nwj@wjavocats.com - www.wjavocats.com - PALAIS C1652",
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  "entities": {
    "people": [
      "Olivier Laude",
      "Ghislaine Maxwell",
      "Jeffrey Epstein",
      "Philippe Jaeglé"
    ],
    "organizations": [
      "Laude Esquicr Champey",
      "Cohen & Gresser LLP",
      "French Ministry of Justice",
      "Department of Justice"
    ],
    "locations": [
      "France",
      "United States of America",
      "Paris"
    ],
    "dates": [
      "March 14th 2021",
      "9 March 2021",
      "1994",
      "1997",
      "03/23/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 171",
      "DOJ-OGR-00002793"
    ]
  },
  "additional_notes": "The document appears to be a formal legal memorandum with a clear structure and formatting. There are no visible redactions or damage."
}