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CaGade2bter TD IZ0cdOhen (Dite Gineh101 O20 2h || @@ 6.2730) 26a Geaigeot A Ob 22 successfully to resist extradition to the United States in relation to the charges in the superseding indictment dated 7 July 2020.”); Def. Mot., Ex. V § 76 (“It would . . . become a matter for the French government to decide on whether or not to issue an extradition decree against Ms. Ghislaine Maxwell.”); id. § 77 (“|I|t is highly unlikely that the French government would refuse to issue and execute an extradition decree against Ms Maxwell. . . .”). Nor has the Defendant presented any cases where courts addressed the question of whether an anticipatory waiver of extradition is enforceable; while she cites cases where defendants offered to waive extradition, the reasoning in those cases turned on other factors and the courts did not dwell on the enforceability of such waivers. See, e.g., United States v. Cirillo, No. 99-1514, 1999 WL 1456536, at *2 (3d Cir. July 13, 1999); United States v. Salvagno, 314 F. Supp. 2d 115, 119 (N.D.N.Y. 2004); United States v. Karni, 298 F. Supp. 2d 129, 132 33 (D.D.C. 2004); United States v. Chen, 820 F. Supp. 1205, 1212 (N.D. Cal. 1992). In those cases, the courts included such waivers as one among several conditions of release, but they did not make any express determination that such waivers are enforceable. On the other hand, some courts have expressly opined that such waivers are unenforceable. See, e.g., United States v. Epstein, 425 F. Supp. 3d 306, 325 (S.D.N.Y. 2019) (describing the “Defense proposal to give advance consent to extradition and waiver of extradition rights” as “an empty gesture.”); United States v. Morrison, No. 16-MR-118, 2016 WL 7421924, at *4 (W.D.N.Y. Dec. 23, 2016) (“Although the defendants have signed a waiver of extradition, such a waiver may not become valid until an extradition request is pending in Canada and may be subject to withdrawal.”’); United States v. Stroh, No. 396-CR-139 (AHN), 2000 WL 1832956, at *5 (D. Conn. Nov. 3, 2000) (“|I|t appears that there is a substantial legal question as to whether any country to which he fled would enforce any waiver of extradition signed under the circumstances presented in this case. At any event, 12 DOJ-OGR-00001221