DOJ-OGR-00001168.jpg

812 KB

Extraction Summary

4
People
3
Organizations
2
Locations
2
Events
3
Relationships
0
Quotes

Document Information

Type: Legal document
File Size: 812 KB
Summary

This legal document is a filing by the Government arguing against a defendant's proposed bail package. The prosecution contends that the defendant is a significant flight risk because a new financial report reveals she has approximately $22 million in assets, far more than previously disclosed, including a $2 million London townhouse and over $4 million in unrestrained funds. The Government further argues that the bond is effectively worthless because two proposed co-signers are UK residents, against whom the bond could not be realistically recovered if the defendant were to flee.

People (4)

Name Role Context
unnamed defendant Defendant
The central figure of the document, argued to be a flight risk due to substantial assets.
unnamed spouse Spouse of the defendant
Mentioned as a potential source of additional resources for the defendant, about which no information has been provid...
unnamed co-signers Proposed co-signers for the defendant's bond
Two are identified as citizens and residents of the United Kingdom, making the bond difficult to enforce.
unnamed attorneys Attorneys for the defendant
Recipients of a $7 million retainer from the defendant.

Organizations (3)

Name Type Context
Pretrial Services Government agency
The agency to which the defendant initially reported a lower asset figure.
Court Judicial body
The judicial body hearing the case and making decisions on detention and bail.
Government Government agency
The prosecuting party arguing against the defendant's release on bail.

Timeline (2 events)

2019-02-08
The Government filed this document arguing against the defendant's proposed bail package.
Court
The defense submitted a financial report showing the defendant has approximately $22 million in assets.
Court

Locations (2)

Location Context
Location of a $2 million townhouse owned by the defendant.
The country of citizenship and residence for two of the defendant's proposed co-signers.

Relationships (3)

The document mentions 'her spouse' and the potential for the spouse to have resources the defendant could access.
unnamed defendant Legal/Financial unnamed co-signers
The document discusses the defendant's 'proposed co-signers' for her bond.
unnamed defendant Professional unnamed attorneys
The document states the defendant paid a '$7 million of the retainer paid to her attorneys'.

Full Extracted Text

Complete text extracted from the document (2,453 characters)

Case 1:17-cr-00330-AJN Document 1002 Filed 02/08/2019 Page 26 of 36
this Court already weighed in favor of detention, and confirmation of that deception only reemphasizes that this defendant cannot be trusted to comply with bail conditions.
Now, the defense has submitted a financial report that reflects the defendant has approximately $22 million in assets—far more than the figure she initially reported to Pretrial Services. (Def. Ex. O). Accepting the financial report at face value, it is clear that the defense’s proposed bail package would leave the defendant with substantial resources to flee the country. Not only would she have millions of dollars in unrestrained assets at her disposal,⁶ but she would also have a $2 million townhouse in London, which she could live in or sell to support herself. In other words, even with the proposed bond—which is only partially secured—the defendant would still have millions of dollars at her disposal. She could absolutely afford to leave her friends and family to lose whatever they may pledge to support her bond, and then repay them much of their losses. In fact, the defendant could transfer money to her proposed co-signers immediately following her release,⁷ given the large sums of money that would be left unrestrained by her proposed bail package.
Moreover, the schedule provided by the defense is notably silent regarding any future revenue streams to which the defendant may have access. The financial report only addresses the defendant’s assets without detailing her income at all. The defendant has similarly provided the Court with no information about what resources her spouse might have access to on a prospective
⁶ In particular, according to the report, the defendant would have more than $4 million in unrestrained funds in accounts, in addition to hundreds of thousands of dollars of jewelry and other items. Moreover, the Government presumes the defendant has not yet spent all $7 million of the retainer paid to her attorneys, which would still belong to the defendant if she fled.
⁷ The Government notes that two of the defendant’s proposed co-signers are citizens and residents of the United Kingdom, against whom the Government could not realistically recover a bond amount. These co-signers have not offered to secure this bond with any cash or property, and as a result, such a bond would effectively be worthless if the defendant were to flee.
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DOJ-OGR-00001168

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