DOJ-OGR-00001495.jpg

738 KB

Extraction Summary

5
People
2
Organizations
3
Locations
2
Events
1
Relationships
0
Quotes

Document Information

Type: Legal document
File Size: 738 KB
Summary

This legal document argues that 'the defendant' presents a clear risk of flight due to international connections, significant financial means, and a transient lifestyle. The defendant has been in hiding since an indictment against Epstein was unsealed in July 2019, making efforts to avoid detection, including an all-cash property purchase in December 2019 through an anonymized LLC. The document concludes that home confinement with electronic monitoring would be inadequate to prevent the defendant from fleeing.

People (5)

Name Role Context
The defendant defendant
Subject of the legal document, accused of flight risk, hiding, making an all-cash property purchase, and having no ti...
Epstein
An indictment against whom was unsealed in July 2019, after which the defendant began hiding.
G Max
Name used by the defendant to register a primary phone number.
Zarger defendant
Defendant in the cited legal case 'United States v. Zarger'.
different person recipient of packages
Person listed on shipping labels for packages ordered by the defendant.

Organizations (2)

Name Type Context
anonymized LLC company
Entity through which the defendant acquired a 156-acre property in an all-cash purchase.
Government government agency
The party submitting that the defendant will not be able to meet her burden of overcoming the presumption of detention.

Timeline (2 events)

December 2019
The defendant acquired a 156-acre property in an all-cash purchase through an anonymized LLC.
Bradford, New Hampshire
July 2019
An indictment against Epstein was unsealed, leading to the defendant going into hiding.

Locations (3)

Location Context
Location where the defendant was hiding out.
Location of the 156-acre property acquired by the defendant.
Country where the defendant has no ties to remain and where she would be detained.

Relationships (1)

The defendant associative/legal Epstein
The defendant began hiding approximately a year prior, since an indictment against Epstein was unsealed in July 2019, suggesting a connection or reaction to Epstein's legal issues.

Full Extracted Text

Complete text extracted from the document (2,190 characters)

Case 1:20-cr-00330-AJN Document 4 Filed 07/02/20 Page 9 of 10
The defendant’s international connections and significant financial means would present a clear risk of flight under normal circumstances, but in this case, the risk of flight is exacerbated by the transient nature of defendant’s current lifestyle. In particular, the defendant has effectively been in hiding for approximately a year, since an indictment against Epstein was unsealed in July 2019. Thereafter, the defendant – who had previously made many public appearances – stopped appearing in public entirely, instead hiding out in locations in New England. Moreover, it appears that she made intentional efforts to avoid detection, including moving locations at least twice, switching her primary phone number (which she registered under the name “G Max”) and email address, and ordering packages for delivery with a different person listed on the shipping label. Most recently, the defendant appears to have been hiding on a 156-acre property acquired in an all-cash purchase in December 2019 (through a carefully anonymized LLC) in Bradford, New Hampshire, an area to which she has no other known connections.
The defendant appears to have no ties that would motivate her to remain in the United States. She has no children, does not reside with any immediate family members, and does not appear to have any employment that would require her to remain in the United States. Nor does she appear to have any permanent ties to any particular location in the United States. As such, the Government respectfully submits that the defendant will not be able to meet her burden of overcoming the presumption of detention, because there are no bail conditions that could reasonably assure the defendant’s continued appearance in this case.
In particular, home confinement with electronic monitoring would be inadequate to mitigate the high risk that the defendant would flee, as she could easily remove a monitoring device. At best, home confinement with electronic monitoring would merely reduce her head start should she decide to flee. See United States v. Zarger, No. 00 Cr. 773, 2000 WL 1134364, at *1
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DOJ-OGR-00001495

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