DOJ-OGR-00019949.pdf

Case 21-58, Document 39-2, 04/01/2021, 3068530, Page90 of 200 k7e2MaxC kjc 1 ties. While she is a naturalized citizen of the United States, 2 she is a citizen of France and the United Kingdom. She grew up 3 in the United Kingdom and has a history of extensive 4 international travel. She owns a property in the 5 United Kingdom. Your Honor, there is a real concern here that 6 the defendant could live beyond the reach of extradition 7 indefinitely. 8 The government has spoken with the Department of 9 Justice attachés in the United Kingdom and France. 10 With respect to France, we have been informed that 11 France will not extradite a French citizen to the United States 12 as a matter of law, even if the defendant is a dual citizen of 13 the United States. 14 As well, we have been informed that there is an 15 extradition treaty between the United Kingdom and the United 16 States. The extradition process would be lengthy, the outcome 17 would be uncertain, and it's very likely that the defendant 18 would not be detained during the pendency of such an 19 extradition proceeding. 20 Those circumstances raise real concerns here. 21 Particularly because the defendant appears to have the 22 financial means to live beyond the reach of extradition 23 indefinitely. As we detailed in our briefing, your Honor, the 24 defendant appears to have access to significant and 25 undetermined and undisclosed wealth. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00019949