{
  "document_metadata": {
    "page_number": "19",
    "document_number": "100",
    "date": "12/18/20",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 100 Filed 12/18/20 Page 19 of 36\nthe jurisdiction of her choosing (i.e., the one to which she chose to flee). The Department of Justice's Office of International Affairs (\"OIA\") is unaware of any country anywhere in the world that would consider an anticipatory extradition waiver binding. Indeed, the defendant's own experts' conclusion—that \"because of these waivers and other factors, it is highly unlikely that she would be able to resist extradition successfully,\" (Mot. at 27)—leaves open the possibility that she could avoid extradition.\nSuch an outcome is virtually a certainty as to France, a country of which the defendant is a citizen and which does not extradite its citizens to the United States. To confirm this fact, after receiving the Renewed Bail Motion, the Government, through OIA, contacted the French Ministry of Justice (\"MOJ\") to clarify whether there is any circumstance under which France would extradite a French citizen to the United States. In response, the MOJ provided the Government with a letter setting forth the relevant law and conclusively stating that France does not extradite its citizens to the United States. That letter in its original French, as well as an English translation of the letter, are attached hereto as Exhibit B. In that letter, the MOJ makes clear that France does not extradite its nationals outside the European Union (regardless of the existence of dual citizenship), including to the United States, and has never derogated from that principle outside the European Union. See Ex. B; see also United States v. Cilins, No. 13 Cr. 315 (WHP), 2013 WL 3802012, at *2 (S.D.N.Y. July 19, 2013) (\"Because France refuses to extradite its citizens, Cilins can avoid prosecution on this Indictment if he can reach French soil.\").\nIn other words, even assuming the Government could locate the defendant, if she flees to France, her citizenship in that country will completely bar her extradition. Any purported waiver of extradition executed in the United States would not be enforceable against the defendant in France because French law embodies an inflexible principle that its citizens will not be extradited\n16\nDOJ-OGR-00002180",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 100 Filed 12/18/20 Page 19 of 36",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "the jurisdiction of her choosing (i.e., the one to which she chose to flee). The Department of Justice's Office of International Affairs (\"OIA\") is unaware of any country anywhere in the world that would consider an anticipatory extradition waiver binding. Indeed, the defendant's own experts' conclusion—that \"because of these waivers and other factors, it is highly unlikely that she would be able to resist extradition successfully,\" (Mot. at 27)—leaves open the possibility that she could avoid extradition.\nSuch an outcome is virtually a certainty as to France, a country of which the defendant is a citizen and which does not extradite its citizens to the United States. To confirm this fact, after receiving the Renewed Bail Motion, the Government, through OIA, contacted the French Ministry of Justice (\"MOJ\") to clarify whether there is any circumstance under which France would extradite a French citizen to the United States. In response, the MOJ provided the Government with a letter setting forth the relevant law and conclusively stating that France does not extradite its citizens to the United States. That letter in its original French, as well as an English translation of the letter, are attached hereto as Exhibit B. In that letter, the MOJ makes clear that France does not extradite its nationals outside the European Union (regardless of the existence of dual citizenship), including to the United States, and has never derogated from that principle outside the European Union. See Ex. B; see also United States v. Cilins, No. 13 Cr. 315 (WHP), 2013 WL 3802012, at *2 (S.D.N.Y. July 19, 2013) (\"Because France refuses to extradite its citizens, Cilins can avoid prosecution on this Indictment if he can reach French soil.\").\nIn other words, even assuming the Government could locate the defendant, if she flees to France, her citizenship in that country will completely bar her extradition. Any purported waiver of extradition executed in the United States would not be enforceable against the defendant in France because French law embodies an inflexible principle that its citizens will not be extradited",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "16",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002180",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "Department of Justice",
      "Office of International Affairs",
      "French Ministry of Justice",
      "European Union"
    ],
    "locations": [
      "France",
      "United States"
    ],
    "dates": [
      "12/18/20",
      "July 19, 2013"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 100",
      "13 Cr. 315 (WHP)",
      "2013 WL 3802012",
      "DOJ-OGR-00002180"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is page 19 of 36."
}