DOJ-OGR-00000997.jpg
524 KB
Extraction Summary
4
People
2
Organizations
4
Locations
4
Events
1
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
524 KB
Summary
This legal document argues that a defendant should be denied bail and home confinement. The prosecution contends the defendant is a significant flight risk due to her access to over $20 million in financial resources, her refusal to account for this wealth, and her ability to maintain relationships remotely. The document cites several legal precedents to argue that GPS ankle-bracelet monitoring is not a reliable means of preventing flight.
People (4)
| Name | Role | Context |
|---|---|---|
| unnamed defendant | Defendant |
The subject of the legal memorandum, argued to be a flight risk due to access to financial resources and foreign ties.
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| Banki | Defendant in a cited case |
Mentioned in the case citation United States v. Banki, where bail was denied to a naturalized citizen from Iran.
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| Zarger | Defendant in a cited case |
Mentioned in the case citation United States v. Zarger, where bail was rejected due to the limitations of electronic ...
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| Benatar | Defendant in a cited case |
Mentioned in the case citation United States v. Benatar, which made a similar point about electronic monitoring.
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Organizations (2)
| Name | Type | Context |
|---|---|---|
| Court | Judicial body |
The judicial body being addressed in the memorandum, urged to deny the defendant's proposal for ankle-bracelet monito...
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| Government | Government agency |
The prosecuting party in the case, arguing against the defendant's release.
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Timeline (4 events)
2000-08-04
Court rejected a defendant's application for bail in the case of United States v. Zarger.
E.D.N.Y.
2002-10-10
Court ruling in the case of United States v. Benatar regarding electronic monitoring.
E.D.N.Y.
2010-01-21
2016-2019
The defendant was associated with over a dozen bank accounts, with balances exceeding $20 million and transfers of hundreds of thousands of dollars.
Locations (4)
| Location | Context |
|---|---|
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Mentioned as the native country of the defendant in the cited case of United States v. Banki.
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The location where the defendant has no children and does not reside with immediate family.
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Southern District of New York, the court district for the cited case United States v. Banki.
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Eastern District of New York, the court district for the cited cases United States v. Zarger and United States v. Ben...
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Relationships (1)
The document states that the Government does not dispute that the defendant 'is close with several of her siblings'.
Key Quotes (2)
"hardly foolproof"Source
— Court in United States v. Banki
(Describing the reliability of electronic monitoring when denying bail.)
DOJ-OGR-00000997.jpg
Quote #1
"at best . . . limits a fleeing defendant’s head start"Source
— Court in United States v. Zarger
(Describing the limited effectiveness of home detention with electronic monitoring.)
DOJ-OGR-00000997.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (2,190 characters)
Case: 20-07005-Adler Document 120 Filed 06/13/20 Page 13 of 19
should raise concerns about the defendant’s access to financial resources that would enable her to flee.
Moreover, and as set forth in the Detention Memorandum, the defendant has been associated with more than a dozen bank accounts from 2016 to the present, and during that period, the maximum total balances of those accounts have exceeded $20 million. Those accounts engaged in transfers in amounts of hundreds of thousands of dollars at a time, including as recently as 2019. To the extent the defendant now refuses to account for her ownership of or access to vast wealth, it is not because it does not exist – it is because she is attempting to hide it.
The defendant’s proposal of ankle-bracelet monitoring should also be of no comfort to the Court. In particular, a GPS monitoring bracelet is of no persuasion because it is does nothing to prevent the defendant’s flight after it has been removed. At best, home confinement and electronic monitoring would reduce her head start should she decide to cut the bracelet and flee. See United States v. Banki, 10 Cr. 008 (JFK), Dkt. 7 (S.D.N.Y. Jan. 21, 2010) (denying bail to a naturalized citizen who was native to Iran, who was single and childless and who faced a statutory maximum of 20 years’ imprisonment, and noting that electronic monitoring is “hardly foolproof.”), aff’d, 369 F. App’x 152 (2d Cir. 2010); United States v. Zarger, No. 00 Cr. 773, 2000 WL 1134364, at *1 (E.D.N.Y. Aug. 4, 2000) (rejecting defendant’s application for bail in part because home detention with electronic monitoring “at best . . . limits a fleeing defendant’s head start”); United States v. Benatar, No. 02 Cr. 099, 2002 WL 31410262, at *3 (E.D.N.Y. Oct. 10, 2002) (same).
The defendant has no children in the United States, she does not reside with any immediate family members, and while the Government does not dispute that she is close with several of her siblings, as her time in hiding makes clear, she is clearly capable of maintaining those relationships remotely, which of course she could continue to do from abroad. Moreover, she has citizenship in
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