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be N Ww ws Oo OY ~] oO Ke) a fan) = be N Ww = Hs Oo a OY a ~] a oO a Ke) 20 21 22 Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 27 of 91 27 k7e2MaxC kjc ties. While she is a naturalized citizen ot F the United States, she is a citizen of France and the United Kingdom. She grew up in the United Kingdom and has a history of extensive international travel. She owns a property in the United Kingdom. Your Honor, there is a real concern here that fF extradition the defendant could live beyond the reach of indefinitely. The government has spoken with the Department of Justice attachés in the United Kingdom and France. With respect to France, we have b n informed that France will not extradite a French citizen to the United States as a matter of law, even if the defendant is a dual citizen of the United States. As well, we have been informed that there is an extradition treaty between the United Kingdom and the United States. The extradition process would be lengthy, the outcome would be uncertain, and it's very likely that the defendant would not be detained during the pendency of extradition proceeding. uch an 0?) Those circumstances raise real concerns here. Particularly because the defendant appears to have the financial means to live beyond the reach of 23 24 25 extradition indefinitely. As we detailed in our briefing, your Honor, the defendant appears to have access to significant and undetermined and undisclosed wealth. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00001904