{
  "document_metadata": {
    "page_number": "12",
    "document_number": "103",
    "date": "12/23/20",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 103 Filed 12/23/20 Page 12 of 15\n\n(Gov. Mem. at 20). The government suggests that purchasing a home using a trust and providing a pseudonym to a real estate broker are indicative of her willingness and ability to live in hiding and somehow forecast Ms. Maxwell's intention to flee. (Id.). These arguments are just further evidence that the government will frame every fact about Ms. Maxwell in the worst possible light. As the defense has already argued extensively in its initial brief, these steps were borne out of necessity to protect Ms. Maxwell and her family from harassment and physical threats.\nMoreover, they are not predictive of flight. There is simply no basis to conclude, based on the measures that Ms. Maxwell was forced to take to protect herself and her family, that she would then willingly abandon that family to become a fugitive from justice. To the contrary, she remained in the country precisely to remain close to them and to defend her case.\n\nD. Refusal of Extradition from France or the United Kingdom Is Highly Unlikely\n\nThe government dismisses Ms. Maxwell's willingness to waive her extradition rights as to France and the United Kingdom as \"meaningless\" because Ms. Maxwell cannot guarantee with absolute certainty that either country will enforce the waiver. (Gov. Mem. at 14). The government misses the point: Ms. Maxwell's willingness to do everything she can to eliminate her ability to refuse extradition to the fullest extent possible demonstrates her firm commitment to remain in this country to face the charges against her and, as Ms. Maxwell's French and U.K. experts confirm, there is every reason to believe that both authorities would consider the waiver as part of any extradition request.\nIn an attempt to counter William Jule's expert report stating it is \"highly unlikely\" that the French government would refuse to extradite Ms. Maxwell (Def. Mem., Ex. V at 2), the government attaches a letter from the French Ministry of Justice (\"MOJ\") that references neither Mr. Jule's report nor Ms. Maxwell, but states generally that the French Code of Criminal Procedure \"absolutely prohibits\" the extradition of a French national. (Gov. Mem., Ex. B). But\n\n8\nDOJ-OGR-00002218",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 103 Filed 12/23/20 Page 12 of 15",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "(Gov. Mem. at 20). The government suggests that purchasing a home using a trust and providing a pseudonym to a real estate broker are indicative of her willingness and ability to live in hiding and somehow forecast Ms. Maxwell's intention to flee. (Id.). These arguments are just further evidence that the government will frame every fact about Ms. Maxwell in the worst possible light. As the defense has already argued extensively in its initial brief, these steps were borne out of necessity to protect Ms. Maxwell and her family from harassment and physical threats.\nMoreover, they are not predictive of flight. There is simply no basis to conclude, based on the measures that Ms. Maxwell was forced to take to protect herself and her family, that she would then willingly abandon that family to become a fugitive from justice. To the contrary, she remained in the country precisely to remain close to them and to defend her case.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "D. Refusal of Extradition from France or the United Kingdom Is Highly Unlikely",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "The government dismisses Ms. Maxwell's willingness to waive her extradition rights as to France and the United Kingdom as \"meaningless\" because Ms. Maxwell cannot guarantee with absolute certainty that either country will enforce the waiver. (Gov. Mem. at 14). The government misses the point: Ms. Maxwell's willingness to do everything she can to eliminate her ability to refuse extradition to the fullest extent possible demonstrates her firm commitment to remain in this country to face the charges against her and, as Ms. Maxwell's French and U.K. experts confirm, there is every reason to believe that both authorities would consider the waiver as part of any extradition request.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "In an attempt to counter William Jule's expert report stating it is \"highly unlikely\" that the French government would refuse to extradite Ms. Maxwell (Def. Mem., Ex. V at 2), the government attaches a letter from the French Ministry of Justice (\"MOJ\") that references neither Mr. Jule's report nor Ms. Maxwell, but states generally that the French Code of Criminal Procedure \"absolutely prohibits\" the extradition of a French national. (Gov. Mem., Ex. B). But",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "8",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002218",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "William Jule",
      "Mr. Jule"
    ],
    "organizations": [
      "French Ministry of Justice"
    ],
    "locations": [
      "France",
      "United Kingdom"
    ],
    "dates": [
      "12/23/20"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 103",
      "DOJ-OGR-00002218"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell. The text is printed and there are no visible stamps or handwritten notes. The document is page 12 of 15."
}