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Case 1:20-cr-00330-AJN Document 100 Filed 12/28/20 Page 27 of 36

basis, in addition to their substantial assets. The financial report submitted by the defense is also careful to note that it does not account for any possible income from inheritances. (Def. Ex. O at 5).
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The financial report further shows that the defendant apparently spent the last five years moving the majority of her assets out of her name by funneling them through trusts to her spouse. That pattern suggests the defendant has used the process of transferring assets as a means to hide her true wealth. As the Renewed Bail Application points out, the defendant currently has approximately $3.4 million worth of assets held in her own name, which is close to the amount of wealth she told Pretrial Services she possessed in July 2020. Importantly, though, that number omits the millions of dollars of assets that she has transferred from her name through trust accounts to her spouse, including funds that were used to purchase the New Hampshire property where the defendant was residing when she was arrested.8 This confirms that the Government was right to be concerned that the defendant had refused to identify her spouse or his assets to Pretrial Services. That practice further demonstrates the defendant’s sophistication in hiding her assets and maintaining assets that are under her control in other names.

In this vein, the financial report suggests that the defendant originally brought more than $20 million to her marriage, but that her husband brought only $200,000.9 (See Def. Ex. O at 10).

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8 On this score, it bears noting that that defendant told Pretrial Services that the property was owned by a corporation, and that she was “just able to stay there.” (Pretrial Services Report at 2). The defendant’s lack of candor does not inspire confidence that she can be trusted to comply with bail conditions.

9 The Government has not been able to verify this financial information—in part because the defense has declined to provide the Government with the spouse’s current banking information—but [REDACTED]

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