DOJ-OGR-00002246(1).jpg

738 KB

Extraction Summary

4
People
3
Organizations
2
Locations
2
Events
1
Relationships
2
Quotes

Document Information

Type: Legal document
File Size: 738 KB
Summary

This legal document is a court's analysis of a defendant's motion for release, focusing on her ties to the United States as a factor in determining flight risk. The court considers letters of support from friends, family, and her spouse, but finds them insufficient to alter its conclusion that she remains a flight risk. The court highlights a key contradiction: the defendant now emphasizes her spousal relationship to argue she has strong ties, despite having claimed she was getting divorced at the time of her arrest.

People (4)

Name Role Context
Dreier Party in a cited case
Mentioned in the case citation 'United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009)'.
Madoff Party in a cited case
Mentioned in the case citation 'United States v. Madoff, 586 F. Supp. 2d 240 (S.D.N.Y. 2009)'.
The Defendant Defendant
The subject of the court's analysis regarding her ties to the United States and flight risk.
Defendant's spouse Spouse
Wrote a letter of support for the Defendant, describing their 'quiet family life' before her arrest.

Organizations (3)

Name Type Context
The Court Government agency
The judicial body analyzing the Defendant's motion and evidence.
Government Government agency
Characterized the Defendant's lifestyle as 'transient'.
Pretrial Services Government agency
Authored a report stating that at the time of her arrest, the Defendant claimed to be getting divorced from her spouse.

Timeline (2 events)

Initial bail hearing where the identity and connection of the Defendant's spouse was withheld from the Court.
The Defendant was arrested. At this time, she was not living with her spouse and claimed to be getting divorced.

Locations (2)

Location Context
The location where the Defendant claims to have significant family and affective ties.
Southern District of New York, mentioned in case citations.

Relationships (1)

The Defendant is now arguing her relationship with her spouse shows deep ties to the country. However, the document notes that at the time of her arrest, she was not living with him and claimed they were getting divorced, which undercuts her current argument.

Key Quotes (2)

"transient"
Source
— Government (Used to describe the Government's characterization of the Defendant's lifestyle.)
DOJ-OGR-00002246(1).jpg
Quote #1
"quiet family life"
Source
— Defendant's spouse (Used in a letter to describe the life the Defendant and her spouse enjoyed, countering the 'transient' lifestyle claim.)
DOJ-OGR-00002246(1).jpg
Quote #2

Full Extracted Text

Complete text extracted from the document (2,212 characters)

Case 1:20-cr-00330-AJN Document 106 Filed 12/30/20 Page 14 of 22
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)).
The Court’s concerns regarding the absence of any dependents, significant family ties, or employment in the United States, meanwhile, apply with somewhat less force in light of the evidence submitted in support of this motion. See id. at 84:4–84:9. The Defendant has submitted a litany of letters of support written by friends and family members. See Def. Mot., Exs. A–N, W–X. These letters, according to the Defendant, support her claim that she has significant ties to the United States and attest to the Defendant’s character. The Defendant places particular emphasis on the letter written by her spouse, whose identity and connection to the Defendant was withheld from the Court at the initial bail hearing. See Def. Mot. at 11–13. In that letter, her spouse expounds on the lives they led before her arrest, noting in particular that the Government’s characterization of the Defendant’s “transient” lifestyle, Dkt. No. 4 at 9, was belied by the “quiet family life” that they had enjoyed. Def. Mot. at 11; see also Def. Mot, Ex. A ¶¶ 4–5. Other letters similarly highlight that the Defendant’s family and affective ties in the United States are stronger than was originally presented to the Court in the initial bail hearing.
These letters substantiate the Defendant’s claim that she has important ties to people in the United States, but they leave unaltered the Court’s conclusion that flight would not pose an insurmountable burden for the Defendant. Among other things, the Defendant now argues that her newly revealed relationship with her spouse signals her deep affective ties in the country, but at the time she was arrested, she was not living with him and claimed to be getting divorced. See Pretrial Services Report at 3. Indeed, she does not propose to live with him were she to be released on bail, undercutting her argument that that relationship would create an insurmountable burden to her fleeing. Furthermore, the fact that she has friends and family in the United States
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DOJ-OGR-00002246

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