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798 KB

Extraction Summary

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

Document Information

Type: Legal document
File Size: 798 KB
Summary

This legal document argues for the defendant's detention by highlighting her evasive behavior and lack of trustworthiness. It cites an instance where she fled from FBI agents and suggests her actions, like wrapping a phone in tin foil, were meant to evade law enforcement. Furthermore, it claims the defendant was deceptive about her wealth, reporting only $3.8 million to Pretrial Services when evidence suggests she has access to far more, indicating a willingness to deceive the Court.

People (2)

Name Role Context
the defendant defendant
The central figure of the document, accused of disobeying FBI agents, evading law enforcement, and being deceptive ab...
defense counsel legal representative
Mentioned in a footnote as having their offer to provide a more fulsome picture of the defendant's finances rejected ...

Organizations (4)

Name Type Context
FBI government agency
Federal agents from the FBI approached the defendant, whose directives she is accused of disobeying.
Pretrial Services government agency
The agency to which the defendant reported her assets as approximately $3.8 million, a claim the document suggests wa...
the Court government agency
The judicial body that previously found the defendant sought to evade law enforcement and rejected defense counsel's ...
the Government government agency
The prosecuting party that expressed doubt about the defendant's reported assets during the initial bail hearing.

Timeline (3 events)

FBI agents approached the defendant, and she fled, an act described as disobeying their directives.
the defendant FBI agents
An initial bail hearing was held where the Government expressed doubt about the defendant's reported assets.
The document refers to the year leading up to the defendant's arrest, during which she allegedly sought to evade law enforcement.
the defendant law enforcement

Relationships (3)

the defendant adversarial FBI
The document states the defendant disobeyed the directives of FBI agents when she fled from them.
the defendant professional Pretrial Services
The defendant reported her assets to Pretrial Services but was allegedly 'less than candid' about the true value.
the defendant legal the Court
The defendant is described as having an 'apparent willingness to deceive' the Court regarding her finances.

Full Extracted Text

Complete text extracted from the document (2,380 characters)

Case 1:20-cr-560880-AJN Document 1002 Filed 06/28/19 Page 25 of 36
(Def. Ex. S ¶ 12). Moreover, the FBI announced themselves as federal agents to the defendant when they first approached her. Thus, even if the defendant was following her private security’s protocol when she fled, she did so knowing that she was disobeying the directives of FBI agents, not members of the media or general public. Those actions raise the very real concern, particularly in light of the terms of her proposed package, that the defendant would prioritize the directives of her private security guards over the directives of federal law enforcement. Further, the act of wrapping a cellphone in tin foil has no conceivable relevance to concerns about the press. The defense argues that the defendant only took those measures because that particular phone number had been released to the public, but that just suggests the defendant believed that was the only number of which law enforcement was aware. In other words, there is still reason to believe, as the Court previously found, that in the year leading up to her arrest, the defendant sought to evade not only the press, but also law enforcement. (Tr. 87).
Third, the defendant has access to significant wealth. At the initial bail hearing, the Government expressed doubt that the defendant’s assets were limited to the approximately $3.8 million she reported to Pretrial Services, and noted that it appeared the defendant was less than candid with Pretrial Services regarding the assets in her control. (Tr. 28-30, 72-73). The finances outlined in the defense submission confirm the Government’s suspicion that the defendant has access to far more than $3.8 million, confirm that the defendant was less than candid with Pretrial Services (and, by extension, the Court) during her interview, and confirm that the defendant is a person of substantial means with vast resources.⁵ The defendant’s apparent willingness to deceive
⁵ As noted above, the Court effectively assumed the defendant had considerably more assets than those disclosed to Pretrial Services in rejecting defense counsel’s repeated offer to provide a more fulsome picture of the defendant’s finances and concluding that even assuming the defense could provide a clearer description of the defendant’s assets, detention was still warranted. (See Tr. 87).
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DOJ-OGR-00020085

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