DOJ-OGR-00002186(1).jpg
788 KB
Extraction Summary
4
People
4
Organizations
0
Locations
4
Events
3
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
788 KB
Summary
This legal document argues for the defendant's detention by highlighting her deceptive behavior and flight risk. It cites her knowing disobedience of FBI directives when she fled, her attempts to evade law enforcement by wrapping a phone in tin foil, and her significant dishonesty regarding her financial assets, which are believed to be far greater than the $3.8 million she disclosed to Pretrial Services.
People (4)
| Name | Role | Context |
|---|---|---|
| unnamed defendant | defendant |
The central figure of the document, accused of disobeying FBI agents, evading law enforcement, and being deceptive ab...
|
| FBI agents | federal agents |
Approached the defendant and gave her directives, which she allegedly disobeyed.
|
| private security guards | private security |
Employed by the defendant; she was allegedly following their protocol when she fled from the FBI.
|
| defense counsel | legal representative |
Mentioned in a footnote as having offered to provide a more fulsome picture of the defendant's finances.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| FBI | government agency |
The Federal Bureau of Investigation, whose agents approached the defendant and whose directives she allegedly disobeyed.
|
| Pretrial Services | government agency |
The agency to which the defendant reported her assets, allegedly in a less than candid manner.
|
| the Court | judicial body |
The judicial entity hearing the case, which found the defendant sought to evade law enforcement and was deceptive abo...
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| the Government | government entity |
Represents the prosecution, which expressed doubt about the defendant's reported assets.
|
Timeline (4 events)
The defendant fled when first approached by FBI agents.
An initial bail hearing was held where the defendant's assets were discussed.
The defendant was arrested.
unnamed defendant
law enforcement
in the year leading up to her arrest
The defendant sought to evade not only the press, but also law enforcement.
Relationships (3)
The document states the defendant disobeyed the directives of FBI agents.
The document states the defendant was 'less than candid' with Pretrial Services regarding her assets.
The document states the defendant was deceptive towards the Court during her interview and that the Court found she had an 'apparent willingness to deceive'.
Full Extracted Text
Complete text extracted from the document (2,378 characters)
Case 1:20-cr-00330-AJN Document 100 Filed 12/18/20 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-00002186
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