Extradition to Slovenia

The United States extradited a Slovene man to stand trial in that country for defrauding Slovenians out of millions of dollars during the 1990s.^[1] The man, Davorin Sadar, fled from his Slovenian trial in 2000, and was arrested in Laredo, Texas in October, 2004, after it was discovered that his visa had expired.^[2] On November 8, 2004, Slovenia asked the United States to extradite Mr. Sadar, and began preparing the necessary documents for extradition.^[3]

There is no named extradition treaty between Slovenia and the United States. However, in 1991, following the collapse of Yugoslavia, Slovenia assumed succession of all conventions that were binding to the former Yugoslavia, including the extradition treaty dated October 25, 1901 between the former Yugoslavia and the United States.^[4] Under the terms of the U.S.-Yugoslavia treaty, each country will “deliver up persons who, having been charged with … any of the crimes and offenses specified in the following article, committed within the jurisdiction of one of the high contracting parties, shall … be found with the territories of the other.”^[5] One of the specified crimes is “obtaining money, valuable securities or other property, knowing the same to have been … fraudulently obtained, when such act is made criminal by the laws of both countries and the amount of money … fraudulently obtained or received, is not less than two hundred dollars.”^[6]

Mr. Sadar’s 1998 indictment says that he defrauded 3,000 investors out of a total of $116 million.^[7]

---

[1] U.S. Extradites Slovene Man Wanted on Fraud Charges, Associated Press, Aug. 9, 2005, [hereinafter U.S. Extradites] available here.
[2] Id.
[3] U.S. to Extradite Prisoner From Slovenia, Associated Press, Nov. 9, 2004, also available here.
[4] See Department of State, Judicial Assistance in the Republic of Slovenia, available here.
[5] Extradition Treaty, Oct. 25, 1901, U.S.-Yugo., art. I, 32 Stat. 1890.
[6] Id. art. II, para. 6.
[7] U.S. Extradites, supra note 1.