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Case 1:20-cr-00330-AJN Document 97 Filed 12/14/20 Page 33 of 45 of release); United States v. Salvagno, 314 F. Supp. 2d 115, 119 (N.D.N.Y. 2004) (ordering each of two defendants to “execute and file with the Clerk of the Court a waiver of extradition applicable to any nation or foreign territory in which he may be found as a condition of his continued release”); United States v. Karni, 298 F. Supp. 2d 129, 132-33 (D.D.C. 2004) (requiring Israeli citizen who lived in South Africa and had “no ties to the United States” to sign waiver of rights not to be extradited under Israeli and South African extradition treaties with United States); United States v. Chen, 820 F. Supp. 1205, 1212 (N.D. Cal. 1992) (ordering as a condition of release that defendants “execute waivers of challenges to extradition from any nation where they may be found”). Moreover, a defendant’s waiver of the right to appeal an extradition order has been recognized as an indication of the defendant’s intent not to flee. See, e.g., United States v. Khashoggi, 717 F. Supp. 1048, 1052 (S.D.N.Y. 1989) (Judge Keenan found defendant’s extradition appeal waiver “manifests an intention to remain here and face the charges against him”). In response to the government’s assertions, Ms. Maxwell has obtained the accompanying reports of experts in United Kingdom and French extradition law, who have analyzed the likelihood that Ms. Maxwell, in the event she were to flee to the United Kingdom or France, would be able to resist extradition to the United States after having executed a waiver of her right to do so. Both have concluded that it is highly unlikely that she would be able to resist extradition successfully. United Kingdom. With respect to the United Kingdom, submitted herewith is a report from David Perry (“Perry Rep.”), a U.K. barrister who is widely considered one of the United Kingdom’s preeminent extradition practitioners. (Perry Rep. Annex B § 2.1) (attached as Exhibit U). Mr. Perry has acted on behalf of many overseas governments in extradition proceedings; has 27 DOJ-OGR-00002005