{
  "document_metadata": {
    "page_number": "4",
    "document_number": "171",
    "date": "03/23/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 171 Filed 03/23/21 Page 4 of 18\ninstead guided by concerns of efficiency. Here, it is unclear whether interlocutory appeal of a district court's decision regarding bail \"divests the court of its control over aspects of the case involved in the appeal.\" United States v. Rodgers, 101 F.3d 247, 251 (2d Cir. 1996). Were it so, a district court would have no authority to remand or modify bail conditions of a defendant released while the government appeals the grant of bail. Such a rule would detract from, rather than promote, judicial economy and would be unworkable in practice.\n\nShould the Court believe it does not have jurisdiction to decide the present bail motion, Ms. Maxwell will move the Circuit to withdraw her notice of appeal without prejudice and thereby remove any theoretical bar to this Court's jurisdiction over the present bail motion. Should the Court summarily deny the present motion on the merits, Ms. Maxwell will file a notice of appeal and request consolidation of both appeals.\n\nRenunciation of Foreign Citizenship is a Valid and Significant Condition of Release\n\nRelying on a letter from the French Ministry of Justice, the government urges the Court to give no weight to Ms. Maxwell's agreement to renounce her foreign citizenship.\n\nBut the letter is wrong on the law and should be disregarded. The letter asserts that the loss of French nationality subsequent to 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 offense and not at the time of the extradition request. As discussed in the opinion from William Jule, French legal counsel (attached as Exhibit A), the government's assertion is entirely incorrect for the following reasons.\n\n- The government's argument goes against the letter of the law.\n- The government's argument goes against the spirit of the law.\n- The government's argument is contradicted by precedent and case law.\n\n(Julie Opinion 6-26).\n3\nDOJ-OGR-00002784",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 171 Filed 03/23/21 Page 4 of 18",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "instead guided by concerns of efficiency. Here, it is unclear whether interlocutory appeal of a district court's decision regarding bail \"divests the court of its control over aspects of the case involved in the appeal.\" United States v. Rodgers, 101 F.3d 247, 251 (2d Cir. 1996). Were it so, a district court would have no authority to remand or modify bail conditions of a defendant released while the government appeals the grant of bail. Such a rule would detract from, rather than promote, judicial economy and would be unworkable in practice.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Should the Court believe it does not have jurisdiction to decide the present bail motion, Ms. Maxwell will move the Circuit to withdraw her notice of appeal without prejudice and thereby remove any theoretical bar to this Court's jurisdiction over the present bail motion. Should the Court summarily deny the present motion on the merits, Ms. Maxwell will file a notice of appeal and request consolidation of both appeals.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Renunciation of Foreign Citizenship is a Valid and Significant Condition of Release",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Relying on a letter from the French Ministry of Justice, the government urges the Court to give no weight to Ms. Maxwell's agreement to renounce her foreign citizenship.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "But the letter is wrong on the law and should be disregarded. The letter asserts that the loss of French nationality subsequent to 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 offense and not at the time of the extradition request. As discussed in the opinion from William Jule, French legal counsel (attached as Exhibit A), the government's assertion is entirely incorrect for the following reasons.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "- The government's argument goes against the letter of the law.\n- The government's argument goes against the spirit of the law.\n- The government's argument is contradicted by precedent and case law.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "(Julie Opinion 6-26).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "3",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002784",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "William Jule"
    ],
    "organizations": [
      "French Ministry of Justice"
    ],
    "locations": [
      "France"
    ],
    "dates": [
      "03/23/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 171",
      "DOJ-OGR-00002784"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a bail motion. The text is printed and there are no visible stamps or handwritten notes. The document is page 4 of 18."
}