DOJ-OGR-00002187(1).jpg
802 KB
Extraction Summary
4
People
3
Organizations
2
Locations
2
Events
3
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
802 KB
Summary
This legal document is a filing by the prosecution arguing against granting bail to a defendant. The government contends that the defendant, who possesses approximately $22 million in assets including a $2 million London townhouse, is a significant flight risk and has previously been deceptive about her finances. The filing also asserts that the proposed bail package is inadequate, particularly because two co-signers are UK residents, making it practically impossible to recover the bond amount if the defendant were to flee.
People (4)
| Name | Role | Context |
|---|---|---|
| defendant | Defendant |
The subject of the legal filing, argued to be a flight risk due to having approximately $22 million in assets.
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| defendant's spouse | Spouse |
Mentioned as a potential source of additional resources not detailed in the defendant's financial report.
|
| defendant's proposed co-signers | Co-signers |
Individuals proposed to secure the defendant's bond. Two are noted as citizens and residents of the United Kingdom.
|
| defendant's attorneys | Attorneys |
Recipients of a $7 million retainer from the defendant.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Court | Judicial body |
The judicial body that previously weighed in favor of detention and is being addressed in this filing.
|
| Pretrial Services | Government agency |
The agency to which the defendant initially reported a lower asset figure than the subsequently disclosed $22 million.
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| The Government | Government agency |
The prosecuting party arguing against the defendant's proposed bail package, citing flight risk.
|
Timeline (2 events)
2020-12-18
The Government filed a document arguing against the defendant's release on bail, citing her substantial assets as a flight risk and the proposed bond as ineffective.
Court
Locations (2)
| Location | Context |
|---|---|
|
Location of the defendant's $2 million townhouse.
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|
|
The country where two of the defendant's proposed co-signers are citizens and residents.
|
Relationships (3)
The document refers to 'her spouse' and the potential resources he might have access to.
The document discusses the defendant's 'proposed co-signers' for her bond and notes two are citizens of the United Kingdom.
The document mentions the '$7 million of the retainer paid to her attorneys' by the defendant.
Full Extracted Text
Complete text extracted from the document (2,450 characters)
Case 1:20-cr-00330-AJN Document 100 Filed 12/18/20 Page 26 of 36
this Court already weighed in favor of detention, and confirmation of that deception only reemphasizes that this defendant cannot be trusted to comply with bail conditions.
Now, the defense has submitted a financial report that reflects the defendant has approximately $22 million in assets—far more than the figure she initially reported to Pretrial Services. (Def. Ex. O). Accepting the financial report at face value, it is clear that the defense’s proposed bail package would leave the defendant with substantial resources to flee the country. Not only would she have millions of dollars in unrestrained assets at her disposal,⁶ but she would also have a $2 million townhouse in London, which she could live in or sell to support herself. In other words, even with the proposed bond—which is only partially secured—the defendant would still have millions of dollars at her disposal. She could absolutely afford to leave her friends and family to lose whatever they may pledge to support her bond, and then repay them much of their losses. In fact, the defendant could transfer money to her proposed co-signers immediately following her release,⁷ given the large sums of money that would be left unrestrained by her proposed bail package.
Moreover, the schedule provided by the defense is notably silent regarding any future revenue streams to which the defendant may have access. The financial report only addresses the defendant’s assets without detailing her income at all. The defendant has similarly provided the Court with no information about what resources her spouse might have access to on a prospective
⁶ In particular, according to the report, the defendant would have more than $4 million in unrestrained funds in accounts, in addition to hundreds of thousands of dollars of jewelry and other items. Moreover, the Government presumes the defendant has not yet spent all $7 million of the retainer paid to her attorneys, which would still belong to the defendant if she fled.
⁷ The Government notes that two of the defendant’s proposed co-signers are citizens and residents of the United Kingdom, against whom the Government could not realistically recover a bond amount. These co-signers have not offered to secure this bond with any cash or property, and as a result, such a bond would effectively be worthless if the defendant were to flee.
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DOJ-OGR-00002187
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