In France , via the Napoleonic code, you are presumed guilty, you have to prove your innocence, you have no right of silence and “illegally” obtained proof is admissible. Finally, access to a lawyer is not always guaranteed. Now granted that DSK has the resources (after all he was staying in a $3,000 a night hotel room) to have a top notch lawyer, it remains that under the French criminal legal system the burden of proof is with the accused, and not the other way around..
Still, my suspicion is that DSK will get a better treatment in U.S. courts than he would in France …
I especially liked the French government’s prohibition for French newspaper to show the Perp walk, after all, anyone with the internet could see not only images but video and commentary. The problem with modern technology!