DOJ-OGR-00001620.jpg
754 KB
Extraction Summary
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People
3
Organizations
1
Locations
2
Events
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Relationships
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Quotes
Document Information
Type:
Legal document
File Size:
754 KB
Summary
This legal document is a memorandum from the Government arguing against the defendant's bail proposal. The Government asserts the defendant is a flight risk due to her considerable but undisclosed financial resources, her failure to submit a financial affidavit, and her history of lying under oath, specifically citing two counts of perjury from a 2016 civil suit. The document urges the Court to view the defendant as untrustworthy and deny the bail proposal, which it claims offers no security for her appearance.
People (1)
| Name | Role | Context |
|---|---|---|
| the defendant | Defendant |
The subject of the legal filing, who is seeking bail and is being argued against by the Government.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Government | government agency |
The prosecuting party in the case, arguing against the defendant's bail proposal.
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| The Court | government agency |
The judicial body being addressed in the memorandum, which will decide on the bail application.
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| Pretrial Services | government agency |
Mentioned in a footnote as the source of information that the defendant indicated she has less than a million dollars...
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Timeline (2 events)
2016
In a civil suit, the defendant allegedly lied repeatedly under oath about her conduct with minors, leading to two counts of perjury.
2020-07-13
The defendant's bail proposal is being considered by the Court, with the Government arguing against it.
Locations (1)
| Location | Context |
|---|---|
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Mentioned in the context of the defendant's assets, which the Government notes she has provided no information about,...
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Relationships (1)
The document is a filing by the Government arguing against the defendant's request for bail, portraying her as untrustworthy and a flight risk.
Full Extracted Text
Complete text extracted from the document (2,242 characters)
Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 10 of 19
spent the last two decades without facing consequences for her criminal actions. For years before her arrest in this case, the defendant likely believed she had gotten away with her crimes. That illusion has now been shattered, and she has a host of new reasons to use her considerable resources to flee.
Moreover, the defendant’s willingness to brazenly lie under oath about her conduct, including some of the conduct charged in the Indictment, strongly suggests her true motive has been and remains to avoid being held accountable for her crimes, rather than to avoid the media. As alleged in the Indictment, in 2016, when the defendant was given the opportunity to address her conduct with minors in the context of a civil suit, she lied repeatedly. Those lies are, of course, the subject of two counts of perjury, and they evidence her willingness to flout the law in order to protect herself. The defendant’s lies under oath should give the Court serious pause about trusting this defendant to comply with conditions of bail.
IV. The Defendant’s Bail Proposal Offers No Security For Her Appearance
In its opening memorandum, the Government highlighted the defendant’s extensive means to flee and her opaque finances. In her response, the defendant’s brief provides zero information about her assets in the United States or abroad. The Court should be troubled by this. First, so far as the Government is aware, the defendant has not filled out a financial affidavit, under penalty of perjury, in connection with her application for bail, meaning that the Court has no reliable insight into the magnitude or scope of the defendant’s resources.² However, what the Court does have are strong indicia that the defendant has access to enormous resources, including the large property she was found on, the private security guard being retained to live with her on that
² The Government understands from Pretrial Services that the defendant has indicated that she has less than a million dollars in bank accounts. The report has not yet been released. As discussed below, the Court should have serious pause before accepting this unverified information.
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DOJ-OGR-00001620
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