DOJ-OGR-00000995.jpg
530 KB
Extraction Summary
2
People
2
Organizations
2
Locations
1
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
530 KB
Summary
This legal document is a filing by the Government arguing against granting bail to a defendant charged with serious crimes. The Government asserts the defendant is a significant flight risk due to her extensive foreign ties, significant assets including a multi-million dollar property in the United Kingdom, and citizenship in a country that does not extradite to the United States. The filing dismisses the proposed bail package, which relies on foreign property as collateral, as providing "effectively no security at all" because the U.S. Government cannot seize foreign assets.
People (2)
| Name | Role | Context |
|---|---|---|
| the defendant | Defendant |
The subject of the legal filing, seeking bail while facing serious criminal charges. Described as having significant ...
|
| proposed co-signers | Bail co-signers |
Mentioned as being friends and relatives of the defendant, but no financial information about them has been provided.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| the Government | Government agency |
The prosecuting party in the case, arguing against the defendant's bail request.
|
| the Court | Judicial body |
The entity responsible for evaluating the defendant's bail request and risk of flight.
|
Timeline (1 events)
2020-07-13
The Government files a memorandum arguing against the defendant's request for bail. The argument centers on the defendant being a flight risk due to significant foreign assets, citizenship in a non-extraditing country, and an inadequate bail package.
United States
Locations (2)
| Location | Context |
|---|---|
|
Location of a multi-million dollar property owned by the defendant and offered as collateral.
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|
|
The jurisdiction where the legal proceedings are taking place and to which the defendant's country of citizenship doe...
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Relationships (1)
The document states that the proposed co-signers are the defendant's "friends and relatives".
Key Quotes (3)
"the defendant’s proposed bail package offers almost no security whatsoever."Source
— the Government
(A central argument in the document asserting the inadequacy of the defendant's bail proposal.)
DOJ-OGR-00000995.jpg
Quote #1
"the Government has no direct way to proceed against foreign property or sureties through bail forfeiture, because the Government cannot seize a foreign citizen’s assets abroad or sell property in another nation based on a United States bail forfeiture judgment."Source
— the Government
(Explaining the legal and practical difficulties that make the foreign property offered as collateral effectively meaningless.)
DOJ-OGR-00000995.jpg
Quote #2
"it is curious that a defendant who appears to have access to millions of dollars has not offered to post a single dime as collateral for the bond she proposes."Source
— the Government
(Questioning the defendant's good faith in the bail proposal, given her apparent wealth.)
DOJ-OGR-00000995.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (2,215 characters)
Case: 20-07005 Document 120 Filed 07/13/20 Page 10 of 19
property, and the multi-million dollar property in the United Kingdom being offered as collateral.
Indeed, it is revealing that the defendant’s memorandum declines to discuss her assets or the assets
to which she plainly has access. Without knowing the full scope of the defendant’s financial
resources, it would be impossible for the Court to even begin to evaluate whether conditions of
bail would mitigate her risk of flight. More importantly, the defendant cannot claim that she has
met her significant burden to rebut the presumption of detention in this case when she has failed
to provide comprehensive, verified financial information under penalty of perjury.
Indeed, it is revealing that the defendant’s memorandum declines to discuss her assets or the assets
to which she plainly has access. Without knowing the full scope of the defendant’s financial
resources, it would be impossible for the Court to even begin to evaluate whether conditions of
bail would mitigate her risk of flight. More importantly, the defendant cannot claim that she has
met her significant burden to rebut the presumption of detention in this case when she has failed
to provide comprehensive, verified financial information under penalty of perjury.
Although the Government submits that no conditions of bail could reasonably assure the
defendant’s continued appearance, the defendant’s proposed bail package offers almost no security
whatsoever. The defendant appears to have significant assets, she has extensive foreign ties and
is a citizen of a country that does not extradite its citizens to the United States, and she is charged
with serious crimes involving the sexual exploitation of minors – and yet, she asks the Court to
grant her bail secured only by a foreign property, which provides effectively no security at all.
defendant’s continued appearance, the defendant’s proposed bail package offers almost no security
whatsoever. The defendant appears to have significant assets, she has extensive foreign ties and
is a citizen of a country that does not extradite its citizens to the United States, and she is charged
with serious crimes involving the sexual exploitation of minors – and yet, she asks the Court to
grant her bail secured only by a foreign property, which provides effectively no security at all.
Indeed, it is curious that a defendant who appears to have access to millions of dollars has
not offered to post a single dime as collateral for the bond she proposes. Instead, as noted, she
offers as security a foreign property, which is effectively meaningless. As a practical matter, the
Government has no direct way to proceed against foreign property or sureties through bail
forfeiture, because the Government cannot seize a foreign citizen’s assets abroad or sell property
in another nation based on a United States bail forfeiture judgment. The Government would be
required to attempt to litigate a property dispute in another country, with a lengthy process and an
uncertain outcome.
not offered to post a single dime as collateral for the bond she proposes. Instead, as noted, she
offers as security a foreign property, which is effectively meaningless. As a practical matter, the
Government has no direct way to proceed against foreign property or sureties through bail
forfeiture, because the Government cannot seize a foreign citizen’s assets abroad or sell property
in another nation based on a United States bail forfeiture judgment. The Government would be
required to attempt to litigate a property dispute in another country, with a lengthy process and an
uncertain outcome.
Additionally, the defendant proffers no information about her proposed co-signers other
than that they are friends and relatives – in particular, she provides no information about the assets
than that they are friends and relatives – in particular, she provides no information about the assets
10
DOJ-OGR-00000995
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