DOJ-OGR-00002191(1).jpg

740 KB

Extraction Summary

5
People
3
Organizations
1
Locations
1
Events
0
Relationships
9
Quotes

Document Information

Type: Legal document
File Size: 740 KB
Summary

This legal document is a court filing arguing against a defendant's motion for bail reconsideration. The author contends that the defense is improperly relitigating issues already decided and that the precedent cases cited (Esposito, Dreier, Madoff) are factually different from the current case. The document emphasizes the Court's findings that the defendant has 'significant foreign connections' and has shown 'sophistication in hiding those resources and herself' as justifications for continued detention.

People (5)

Name Role Context
Jackson Party in a legal case
Mentioned in the case citation 'Jackson v. Goord, 664 F. Supp. 2d 307, 313 (S.D.N.Y. 2009)'.
Goord Party in a legal case
Mentioned in the case citation 'Jackson v. Goord, 664 F. Supp. 2d 307, 313 (S.D.N.Y. 2009)'.
Esposito Defendant
Mentioned in the case citation 'United States v. Esposito, 309 F. Supp. 3d 24 (S.D.N.Y. 2018)' as a case distinguishe...
Dreier Defendant
Mentioned in the case citation 'United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009)' as a case described as ...
Madoff Defendant
Mentioned in the case citation 'United States v. Madoff, 586 F. Supp. 2d 240 (S.D.N.Y. 2009)' as a case distinguished...

Organizations (3)

Name Type Context
The Court Government agency
Referenced throughout the document as the decision-making judicial body that denied bail and is being asked to recons...
United States Government agency
Appears as the prosecuting party in the cited cases 'United States v. Esposito', 'United States v. Dreier', and 'Unit...
DOJ-OGR Government agency
Appears as a document identifier in the footer (DOJ-OGR-00002191), likely referring to the Department of Justice.

Timeline (1 events)

2020-07-14
A hearing where the defense discussed cases to argue for bail conditions.
The Court the defense

Locations (1)

Location Context
Mentioned in multiple case citations, referring to the United States District Court for the Southern District of New ...

Key Quotes (9)

"high-profile defendants with financial means and foreign citizenship."
Source
— The defense (as quoted by the author) (Describing the type of defendants for whom the defense argues bail conditions have been previously approved.)
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Quote #1
"A motion for reconsideration may not be used . . . as a vehicle for relitigating issues already decided by the Court."
Source
— Jackson v. Goord case (A legal principle cited to argue against the defense's efforts to raise precedent already considered by the Court.)
DOJ-OGR-00002191(1).jpg
Quote #2
"serious and high-profile prosecutions where the courts, over the government’s objection, granted bail to defendants with significant financial resources."
Source
— The defense (as quoted by the author) (The defense's characterization of cases it is citing as precedent.)
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Quote #3
"crucial factual differences"
Source
— The Court (The Court's reason for distinguishing the current defendant's case from those cited by the defense.)
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Quote #4
"not on point and not persuasive"
Source
— The Court (The Court's description of the cases cited by the defense (Esposito, Dreier, Madoff).)
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Quote #5
"significant foreign connections."
Source
— The Court (One of the reasons the Court distinguished the current defendant from others.)
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Quote #6
"have been based on the resources available to defendant, not foreign connections or experience and a record of hiding from being found"
Source
— The Court (The Court's reasoning for distinguishing the Esposito case, where the flight risk was different.)
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Quote #7
"the defendant had already been released on a bail package agreed to by the parties for a considerable period of time before the government sought detention"
Source
— The Court (The Court's reasoning for distinguishing the Madoff case.)
DOJ-OGR-00002191(1).jpg
Quote #8
"the defendant not only has significant financial resources, but has demonstrated sophistication in hiding those resources and herself."
Source
— The Court (A finding by the Court that supports the decision to detain the defendant.)
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Quote #9

Full Extracted Text

Complete text extracted from the document (2,200 characters)

Case 1:20-cr-00330-AJN Document 100 Filed 12/18/20 Page 30 of 36
In urging a different conclusion, the defense again cites the same cases discussed in its initial briefing and at the July 14, 2020 hearing to argue that the proposed bail conditions are consistent with or exceed those approved by courts in this Circuit for “high-profile defendants with financial means and foreign citizenship.” (Mot. at 34; see Dkt. 18 at 16, 21; Tr. 48-51). The Court should reject the defense’s efforts to raise the same precedent that the Court already took into consideration when denying bail. “A motion for reconsideration may not be used . . . as a vehicle for relitigating issues already decided by the Court.” Jackson v. Goord, 664 F. Supp. 2d 307, 313 (S.D.N.Y. 2009) (internal quotation marks omitted). The Court already considered and rejected the defendant’s efforts to liken her case to other “serious and high-profile prosecutions where the courts, over the government’s objection, granted bail to defendants with significant financial resources.” (Tr. 88). Noting “crucial factual differences,” the Court described those cases, including United States v. Esposito, 309 F. Supp. 3d 24 (S.D.N.Y. 2018), United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009), and United States v. Madoff, 586 F. Supp. 2d 240 (S.D.N.Y. 2009), as “not on point and not persuasive,” and distinguished the defendant for a number of reasons, including the defendant’s “significant foreign connections.” (Tr. 88; see id. (distinguishing Esposito where the risk of flight appeared to “have been based on the resources available to defendant, not foreign connections or experience and a record of hiding from being found”); id. (distinguishing Madoff where “the defendant had already been released on a bail package agreed to by the parties for a considerable period of time before the government sought detention”)).
The Court already engaged in a fact-specific analysis in ordering the defendant detained. Among the reasons provided, the Court found that the “the defendant not only has significant financial resources, but has demonstrated sophistication in hiding those resources and herself.”
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DOJ-OGR-00002191

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