mirror-epstein-docs/results/IMAGES001/DOJ-OGR-00002147.json

{
  "document_metadata": {
    "page_number": "23",
    "document_number": "97-22",
    "date": "12/14/20",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 23 of 30\nWilliam JULIÉ\navocat à la cour - attorney at law\na United States citizen. Thus, there is no precedent to draw from in that regard. However, it is our view that under the specific and unique facts of this case, it is highly unlikely that the French government would refuse to issue and execute an extradition decree against Ms Maxwell because of several critical factors.\n78. First, under the applicable Extradition Treaty between the USA and France, a State party may refuse extradition on the basis of nationality, however if it does so, it is obliged to prosecute the requested person itself, on the basis of the conduct and the allegations contained in the request. In the case of Ms Ghislaine Maxwell, it is highly unlikely that the French government would be inclined to conducting such prosecution, considering that all the relevant facts were committed in the USA, a long time ago, and that witnesses are also located in the USA.\n79. Secondly, France is mindful to preserve its good extradition relations with the United States, as evidenced by a number of recent cases we reviewed or conducted in which French competent authorities proved highly cooperative with US authorities. If Ms Ghislaine Maxwell were to flee to France, and the USA decided to issue an extradition request, it would be difficult for French authorities - from a diplomatic point of view - to deny such an extradition request, considering that no legal bar applies.37\n80. Thirdly, the fact that Ms Ghislaine Maxwell also holds American nationality, and has substantial ties to the USA, would, in all likelihood, be taken into account by the French government as one more element weighing in favor of extradition.\n81. Similarly, and fourthly, the fact that Ms Ghislaine Maxwell signed a legally binding Waiver under US law, and would have subsequently fled to France in violation of her bail conditions, could equally be taken into account by the French government as an incentive not to grant Ms Ghislaine Maxwell the benefit of her French nationality as a ban to extradition.\nWilliam Julié\n37 Of the 36 reported Supreme Court decisions involving extradition requests from the United States in the last 20 years, the French authorities granted extradition in 34 of these cases. Lower court decisions granting extradition were quashed only twice for procedural deficiencies not at issue in this case.\n51, rue Ampère - 75017 paris - tél. 01 88 33 51 80 - fax. 01 88 33 51 81 www.wjavocats.com - palais C1652 wj@wjavocats.com - 22 DOJ-OGR-00002147",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 97-22 Filed 12/14/20 Page 23 of 30",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "William JULIÉ\navocat à la cour - attorney at law",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "a United States citizen. Thus, there is no precedent to draw from in that regard. However, it is our view that under the specific and unique facts of this case, it is highly unlikely that the French government would refuse to issue and execute an extradition decree against Ms Maxwell because of several critical factors.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "78. First, under the applicable Extradition Treaty between the USA and France, a State party may refuse extradition on the basis of nationality, however if it does so, it is obliged to prosecute the requested person itself, on the basis of the conduct and the allegations contained in the request. In the case of Ms Ghislaine Maxwell, it is highly unlikely that the French government would be inclined to conducting such prosecution, considering that all the relevant facts were committed in the USA, a long time ago, and that witnesses are also located in the USA.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "79. Secondly, France is mindful to preserve its good extradition relations with the United States, as evidenced by a number of recent cases we reviewed or conducted in which French competent authorities proved highly cooperative with US authorities. If Ms Ghislaine Maxwell were to flee to France, and the USA decided to issue an extradition request, it would be difficult for French authorities - from a diplomatic point of view - to deny such an extradition request, considering that no legal bar applies.37",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "80. Thirdly, the fact that Ms Ghislaine Maxwell also holds American nationality, and has substantial ties to the USA, would, in all likelihood, be taken into account by the French government as one more element weighing in favor of extradition.",
      "position": "body"
    },
    {
      "type": "printed",
      "content": "81. Similarly, and fourthly, the fact that Ms Ghislaine Maxwell signed a legally binding Waiver under US law, and would have subsequently fled to France in violation of her bail conditions, could equally be taken into account by the French government as an incentive not to grant Ms Ghislaine Maxwell the benefit of her French nationality as a ban to extradition.",
      "position": "body"
    },
    {
      "type": "signature",
      "content": "William Julié",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "37 Of the 36 reported Supreme Court decisions involving extradition requests from the United States in the last 20 years, the French authorities granted extradition in 34 of these cases. Lower court decisions granting extradition were quashed only twice for procedural deficiencies not at issue in this case.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "51, rue Ampère - 75017 paris - tél. 01 88 33 51 80 - fax. 01 88 33 51 81 www.wjavocats.com - palais C1652 wj@wjavocats.com - 22 DOJ-OGR-00002147",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "William JULIÉ",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "French government",
      "US authorities",
      "Supreme Court"
    ],
    "locations": [
      "USA",
      "France",
      "Paris"
    ],
    "dates": [
      "12/14/20"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "97-22",
      "DOJ-OGR-00002147"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the extradition case of Ghislaine Maxwell. The text is mostly printed, with a signature at the bottom. There are no visible stamps or handwritten annotations."
}