DOJ-OGR-00001613.jpg
724 KB
Extraction Summary
2
People
2
Organizations
3
Locations
2
Events
2
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
724 KB
Summary
This document is a legal filing from the government arguing against a defendant's proposed bail package. The government asserts the defendant is a significant flight risk due to her opaque finances, access to extraordinary resources abroad, and demonstrated skill at hiding. The proposed $5 million bond is deemed insufficient because it relies on an overseas property as collateral and six unidentified co-signers whose ability or incentive to pay is unknown.
People (2)
| Name | Role | Context |
|---|---|---|
| the defendant | Defendant |
The subject of the legal filing, who has proposed a bail package that the government is arguing against.
|
| unidentified co-signers | Co-signer |
Six unidentified individuals proposed by the defendant to secure a $5 million bond.
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Organizations (2)
| Name | Type | Context |
|---|---|---|
| the Court | Government agency |
The judicial body presiding over the case (Case 1:20-cr-00330-AJN).
|
| the Government | Government agency |
The prosecuting party in the case, arguing against the defendant's release on bail.
|
Timeline (2 events)
2020-07-13
The government filed a document (Document 22) in Case 1:20-cr-00330-AJN arguing against the defendant's bail proposal.
The defendant proposed a bail package that includes pledging a property outside the U.S. and using six unidentified co-signers for a $5 million bond.
Locations (3)
| Location | Context |
|---|---|
|
Mentioned as a place where the defendant has the ability to live beyond the reach of extradition.
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The jurisdiction of the court. A property proposed as collateral is noted as being beyond its territory and judicial ...
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The location where the defendant proposes to live if released on bail.
|
Relationships (2)
The Government is the prosecuting party arguing against the defendant's motion for bail.
The defendant has proposed six unidentified individuals to act as co-signers on her $5 million bail bond.
Full Extracted Text
Complete text extracted from the document (2,149 characters)
Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 3 of 19
domestically and abroad; (3) her finances are completely opaque, as her memorandum pointedly
declines to provide the Court with information about her financial resources; and (4) she appears
to be skilled at living in hiding. These are glaring red flags, even before the Court considers the
gravity of the charges in this case and the serious penalties the defendant faces if convicted at trial.
Instead of attempting to address the risks of releasing a defendant with apparent access to
extraordinary financial resources, who has the ability to live beyond the reach of extradition in
France, and who has already demonstrated a willingness and ability to live in hiding, the defendant
instead proposes a bail package that amounts to little more than an unsecured bond. Among other
things, the proposed bail package contemplates the defendant pledging as the sole security a
property that is beyond the territory and judicial reach of the United States, and which therefore is
of no value as collateral. She proposes six unidentified co-signers, an unknown number of whom
even reside in the United States, and none of whose assets are identified. The Court and the
Government have no information whatsoever regarding whether these co-signers would be able to
able to pay the proposed $5 million bond should the defendant flee – or if, of equal concern, the
co-signers are themselves so wealthy that it would be no financial burden whatsoever to do so.
The defendant does not identify what residence she proposes to live at in the Southern District of
New York, nor does she identify any meaningful ties to the area. And most importantly, the
defendant’s memorandum provides the Court with no information whatsoever about her own
finances or her access to the wealth of others, declining to provide the Court the very information
that would inform any decision about whether a bond is even meaningful to the defendant – and
which the Government submits would reveal the defendant’s financial means to flee and live
comfortably abroad for the rest of her life.
declines to provide the Court with information about her financial resources; and (4) she appears
to be skilled at living in hiding. These are glaring red flags, even before the Court considers the
gravity of the charges in this case and the serious penalties the defendant faces if convicted at trial.
Instead of attempting to address the risks of releasing a defendant with apparent access to
extraordinary financial resources, who has the ability to live beyond the reach of extradition in
France, and who has already demonstrated a willingness and ability to live in hiding, the defendant
instead proposes a bail package that amounts to little more than an unsecured bond. Among other
things, the proposed bail package contemplates the defendant pledging as the sole security a
property that is beyond the territory and judicial reach of the United States, and which therefore is
of no value as collateral. She proposes six unidentified co-signers, an unknown number of whom
even reside in the United States, and none of whose assets are identified. The Court and the
Government have no information whatsoever regarding whether these co-signers would be able to
able to pay the proposed $5 million bond should the defendant flee – or if, of equal concern, the
co-signers are themselves so wealthy that it would be no financial burden whatsoever to do so.
The defendant does not identify what residence she proposes to live at in the Southern District of
New York, nor does she identify any meaningful ties to the area. And most importantly, the
defendant’s memorandum provides the Court with no information whatsoever about her own
finances or her access to the wealth of others, declining to provide the Court the very information
that would inform any decision about whether a bond is even meaningful to the defendant – and
which the Government submits would reveal the defendant’s financial means to flee and live
comfortably abroad for the rest of her life.
2
DOJ-OGR-00001613
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