DOJ-OGR-00002177.jpg

742 KB

Extraction Summary

2
People
2
Organizations
2
Locations
2
Events
1
Relationships
1
Quotes

Document Information

Type: Legal document
File Size: 742 KB
Summary

This legal document, part of a court filing, argues for the continued detention of a defendant, asserting she is a flight risk. The argument is based on her significant foreign ties, including citizenship in three countries, foreign property, and bank accounts, as well as her lack of strong ties to the U.S. and inconsistent statements made to Pretrial Services regarding her marital status.

People (2)

Name Role Context
defendant defendant
The subject of the legal filing, argued to be a flight risk due to foreign ties, wealth, and inconsistent statements.
defendant's spouse spouse
Mentioned in relation to the defendant's inconsistent statements about their marriage and his recent decision to supp...

Organizations (2)

Name Type Context
Court government agency
The judicial body that made the original detention decision and is considering the Renewed Bail Motion.
Pretrial Services government agency
The agency to which the defendant made statements about her employment, children, and marital status, as documented i...

Timeline (2 events)

The original hearing where the defendant's detention was decided.
United States
The defendant was arrested, at which time she made statements to Pretrial Services.
United States

Locations (2)

Location Context
The country where the defendant has resided, holds citizenship, and is currently detained. The document discusses her...
Implied by the mention of "French law" at the beginning of the document.

Relationships (1)

defendant marital defendant's spouse
The document discusses their marriage, the defendant's prior statement that she was divorcing him, and his recent decision to come forward and support her bail application.

Key Quotes (1)

"in the process of divorcing her husband."
Source
— defendant (A statement made by the defendant to Pretrial Services at the time of her arrest, which is now being used to argue her statements are inconsistent.)
DOJ-OGR-00002177.jpg
Quote #1

Full Extracted Text

Complete text extracted from the document (2,243 characters)

Case 1:20-cr-00330-AJN Document 100 Filed 12/18/20 Page 16 of 36
French law, is simply incorrect. Accordingly, the defendant’s foreign ties, wealth, and skill at avoiding detection continue to weigh in favor of detention.
First, there can be no serious dispute that the defendant has foreign ties. She is a citizen of three countries and holds three passports. As was already noted at the original hearing and is again evidenced in the Renewed Bail Application, the defendant has close relatives and friends who live abroad, as well as a multi-million dollar foreign property and at least one foreign bank account. (Tr. 83). In an attempt to minimize the defendant’s foreign ties, the defense emphasizes the defendant’s relatives and friends in the United States, history of residence in the United States, and United States citizenship. But the Court was already aware of those factors when making its original detention decision. (See Tr. 84; Dkt. 18 at 2, 12). The letters and documentation included in the Renewed Bail Motion simply prove points that were not in dispute. What that documentation does not do, however, is suggest that the defendant has the kind of ties to this country that come with any employment in the United States or any dependents living here. Indeed, as noted in the Pretrial Services Report, the defendant stated in July that she has no children and has no current employment. (Pretrial Services Report at 3).
The Renewed Bail Motion fails to establish sufficiently strong ties to the United States that would prevent her from fleeing. Although the defendant now claims her marriage would keep her in the United States, her motion does not address the plainly inconsistent statements she made to Pretrial Services at the time of her arrest, when, as documented in the Pretrial Services Report, the defendant said she was “in the process of divorcing her husband.” (Id.). On this point, it bears noting that the defendant’s motion asks that she be permitted to live with [REDACTED] if granted bail, not her spouse. Moreover, the fact that the defendant’s spouse has only now come forward to support the defendant should be afforded little weight given that he refused to come forward at the
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DOJ-OGR-00002177

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