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812 KB

Extraction Summary

4
People
3
Organizations
2
Locations
3
Events
5
Relationships
0
Quotes

Document Information

Type: Legal document
File Size: 812 KB
Summary

This legal document discusses the defendant's financial status and its implications for her bail conditions. It highlights that the defendant possesses significantly more assets ($22 million, including a $2 million London townhouse and over $4 million in unrestrained funds) than initially reported, making her a substantial flight risk. The document also raises concerns about the effectiveness of the proposed bail bond, noting that some co-signers are UK residents who haven't offered cash or property, and the defendant's $7 million attorney retainer is presumed unspent.

People (4)

Name Role Context
defendant Defendant in a legal case
The individual whose assets, bail conditions, and flight risk are being discussed.
co-signers Proposed co-signers for bail bond
Individuals proposed to support the defendant's bond, two of whom are citizens and residents of the United Kingdom an...
spouse Defendant's spouse
Mentioned as a potential source of financial resources for the defendant, about which the Court has no information.
attorneys Defendant's legal counsel
Received a $7 million retainer from the defendant.

Organizations (3)

Name Type Context
Court government agency
The judicial body that weighed in favor of detention and is assessing the defendant's compliance with bail conditions.
Pretrial Services government agency
The entity to whom the defendant initially reported her assets.
Government government agency
The prosecuting body, which presumes the defendant has not spent her $7 million retainer and notes issues with the pr...

Timeline (3 events)

Court weighed in favor of detention and reemphasized that the defendant cannot be trusted to comply with bail conditions due to deception.
The defense submitted a financial report reflecting the defendant's assets.
defense defendant
Defendant initially reported assets to Pretrial Services.

Locations (2)

Location Context
Location of a $2 million townhouse owned by the defendant.
Citizenship and residency of two of the defendant's proposed co-signers.

Relationships (5)

defendant legal/financial support (proposed) co-signers
Co-signers are proposed to support the defendant's bail bond, but their ability to secure it is questioned due to lack of offered cash/property and UK residency.
defendant personal/financial spouse
The Court lacks information on financial resources the spouse might have access to, which could benefit the defendant.
defendant professional/client-attorney attorneys
Defendant paid a $7 million retainer to her attorneys, which the Government believes is still available to her.
defendant legal Court
The Court is assessing the defendant's trustworthiness and compliance with bail conditions, noting her deception regarding assets.
defendant legal/reporting Pretrial Services
Defendant initially reported assets to Pretrial Services, a figure later contradicted by a defense financial report.

Full Extracted Text

Complete text extracted from the document (2,449 characters)

Case: 20-cr-560(AJN) Document 1002 Filed 08/18/20 Page 26 of 36
this Court already weighed in favor of detention, and confirmation of that deception only
reemphasizes that this defendant cannot be trusted to comply with bail conditions.
Now, the defense has submitted a financial report that reflects the defendant has
approximately $22 million in assets—far more than the figure she initially reported to Pretrial
Services. (Def. Ex. O). Accepting the financial report at face value, it is clear that the defense’s
proposed bail package would leave the defendant with substantial resources to flee the country.
Not only would she have millions of dollars in unrestrained assets at her disposal,⁶ but she would
also have a $2 million townhouse in London, which she could live in or sell to support herself. In
other words, even with the proposed bond—which is only partially secured—the defendant would
still have millions of dollars at her disposal. She could absolutely afford to leave her friends and
family to lose whatever they may pledge to support her bond, and then repay them much of their
losses. In fact, the defendant could transfer money to her proposed co-signers immediately
following her release,⁷ given the large sums of money that would be left unrestrained by her
proposed bail package.
Moreover, the schedule provided by the defense is notably silent regarding any future
revenue streams to which the defendant may have access. The financial report only addresses the
defendant’s assets without detailing her income at all. The defendant has similarly provided the
Court with no information about what resources her spouse might have access to on a prospective
⁶ In particular, according to the report, the defendant would have more than $4 million in
unrestrained funds in accounts, in addition to hundreds of thousands of dollars of jewelry and other
items. Moreover, the Government presumes the defendant has not yet spent all $7 million of the
retainer paid to her attorneys, which would still belong to the defendant if she fled.
⁷ The Government notes that two of the defendant’s proposed co-signers are citizens and residents
of the United Kingdom, against whom the Government could not realistically recover a bond
amount. These co-signers have not offered to secure this bond with any cash or property, and as
a result, such a bond would effectively be worthless if the defendant were to flee.
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DOJ-OGR-00020086

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