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DOJ-OGR-00001624.jpg
718 KB
Extraction Summary
7
People
1
Organizations
3
Locations
5
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
718 KB
Summary
This legal document argues against a defendant's request for bail. It contends the defendant is a significant flight risk due to substantial financial resources, international ties, and a lack of connection to the United States. The document also asserts that the COVID-19 pandemic is not a sufficient reason for release, citing several legal precedents from New York district courts that have denied similar applications.
People (7)
| Name | Role | Context |
|---|---|---|
| Boustani | Defendant |
Mentioned as the defendant in the cited case United States v. Boustani.
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| Zarrab | Defendant |
Mentioned as the defendant in the cited case United States v. Zarrab.
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| Paulino | Defendant |
Mentioned as the defendant in the cited case United States v. Paulino.
|
| Gardephe, J. | Judge |
Identified as the judge who denied a bail application in the United States v. Paulino case.
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| Ortiz | Defendant |
Mentioned as the defendant in the cited case United States v. Ortiz.
|
| Nunez | Defendant |
Mentioned as the defendant in the cited case United States v. Nunez.
|
| Ramos, J. | Judge |
Identified as the judge in the United States v. Nunez case.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| Court | Government agency |
The judicial body being addressed in the document and cited in various legal cases.
|
Timeline (5 events)
2020-04-10
2020-04-13
Ruling by Judge Gardephe in the case of United States v. Paulino, denying a bail application.
S.D.N.Y.
Locations (3)
| Location | Context |
|---|---|
|
Mentioned in the context of the defendant's lack of ties to the country.
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|
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Eastern District of New York, the court district for the United States v. Boustani case.
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Southern District of New York, the court district for several cited cases (Zarrab, Paulino, Ortiz, Nunez).
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Relationships (1)
The document is a legal filing arguing against the defendant's release on behalf of the United States government.
Key Quotes (3)
"[T]he combination of Defendant’s alleged deceptive actions, access to substantial financial resources, frequent international travel, complete lack of ties to the United States, and extensive ties to foreign countries without extradition demonstrates Defendant poses a serious risk of flight."Source
— Court in United States v. Boustani
(Quoted to support the argument that the current defendant is a flight risk.)
DOJ-OGR-00001624.jpg
Quote #1
"[a]s serious as it is, the outbreak of COVID-19 simply does not override the statutory detention provisions [of the Bail Reform Act]"Source
— Judge Gardephe in United States v. Paulino
(Quoted to argue that the COVID-19 pandemic is not a sufficient reason for the defendant's release.)
DOJ-OGR-00001624.jpg
Quote #2
"[B]ecause there is a pandemic does not mean that the jailhouse doors ought to be thrown open"Source
— Judge Ramos in United States v. Nunez
(Quoted from the Ortiz case, which in turn quoted the Nunez case, to support the argument against release due to the pandemic.)
DOJ-OGR-00001624.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,069 characters)
Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 14 of 19
a country that does not extradite its citizens, has access to untold financial resources, and has every motivation to escape accountability for her appalling crimes. See United States v. Boustani, 356 F. Supp. 3d 246, 255 (E.D.N.Y. 2019) (“[T]he combination of Defendant’s alleged deceptive actions, access to substantial financial resources, frequent international travel, complete lack of ties to the United States, and extensive ties to foreign countries without extradition demonstrates Defendant poses a serious risk of flight.”) (citing United States v. Zarrab, No. 15 Cr. 867 (RMB), 2016 WL 3681423, at *8 (S.D.N.Y. June 16, 2016)). The defendant’s proposed bail package is essentially nothing more than an unenforceable promise to return to Court. Given the gravity of the charged crimes, the defendant’s substantial resources, her willingness to evade detection, and her lies under oath, the Court should take the proposed bail package for what it is worth: nothing.
V. The COVID-19 Pandemic Does Not Warrant The Defendant’s Release
Finally, the current pandemic is not a reason to release this defendant. Indeed, courts in this district have regularly rejected applications for release based on assertions about the generalized risks of COVID-19. See, e.g., United States v. Paulino, No. 19 Cr. 54 (PGG), 2020 WL 1847914, at *6 (S.D.N.Y. Apr. 13, 2020) (Gardephe, J.) (denying bail application by defendant with hypertension, stating that “[a]s serious as it is, the outbreak of COVID-19 simply does not override the statutory detention provisions [of the Bail Reform Act]” (internal quotation omitted)); United States v. Ortiz, 19 Cr. 198 (KPF), 2020 WL 2539124, at *2 (S.D.N.Y. May 19, 2020) (quoting United States v. Nunez, No. 20 Cr. 239 (ER) (S.D.N.Y. Apr. 10, 2020) (Ramos, J.) (“[B]ecause there is a pandemic does not mean that the jailhouse doors ought to be thrown open”)). Significantly, the defendant has not claimed that she is at a higher risk from COVID-19
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