DOJ-OGR-00001493.jpg
740 KB
Extraction Summary
4
People
4
Organizations
5
Locations
2
Events
0
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
740 KB
Summary
This legal document, part of a court filing, argues for the detention of a defendant by highlighting her characteristics as a significant flight risk. The prosecution points to the defendant's extensive international ties, including being born in France, raised in the United Kingdom, and holding citizenship and passports for the US, UK, and France. Her frequent international travel, including at least fifteen flights in the last three years, and her financial means are presented as evidence supporting the argument that she could easily flee and live abroad.
People (4)
| Name | Role | Context |
|---|---|---|
| the defendant | Defendant |
The subject of the legal filing, described as a flight risk due to international ties, multiple citizenships (US, UK,...
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| Chief | Party in a legal case |
Mentioned in the case citation 'United States v. Chief, 438 F.3d 920, 922-25 (9th Cir. 2006)'.
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| Pierre-Louis | Party in a legal case |
Mentioned in the case citation 'United States v. Pierre-Louis, No. 16 Cr. 541 (CM), 2018 WL 4043140, at *1 (S.D.N.Y. ...
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| minor victim | Victim |
Mentioned in the context of the statute of limitations for sexual offenses involving minors.
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Organizations (4)
| Name | Type | Context |
|---|---|---|
| Congress | Government agency |
Mentioned as having extended the statute of limitations for sex offenses involving minors.
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| United States Customs and Border Protection | Government agency |
Abbreviated as 'CBP', their travel records are cited as evidence of the defendant's frequent international travel and...
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| 9th Cir. | Court |
The United States Court of Appeals for the Ninth Circuit, cited in the case 'United States v. Chief'.
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| S.D.N.Y. | Court |
The United States District Court for the Southern District of New York, cited in the case 'United States v. Pierre-Lo...
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Timeline (2 events)
2002
2017-2020
The defendant engaged in frequent international travel, including at least fifteen international flights in the last three years.
International (including United Kingdom, Japan, and Qatar)
Locations (5)
| Location | Context |
|---|---|
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The defendant's country of birth and one of her citizenships. She appears to possess a passport from France.
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The country where the defendant was raised, attended school, and holds citizenship. She has traveled there and appear...
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The country where the defendant became a naturalized citizen in 2002 and appears to possess a passport from.
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One of the locations the defendant has traveled to in the last three years.
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One of the locations the defendant has traveled to in the last three years.
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Full Extracted Text
Complete text extracted from the document (2,191 characters)
Case 1:20-cr-00330-AJN Document 4 Filed 07/02/20 Page 7 of 10
date of the amendment,¹ to permit a prosecution at any point during the lifetime of the minor victim. See United States v. Chief, 438 F.3d 920, 922-25 (9th Cir. 2006) (finding that because Congress extended the statute of limitations for sex offenses involving minors during the time the previous statute was still running, the extension was permissible); United States v. Pierre-Louis, No. 16 Cr. 541 (CM), 2018 WL 4043140, at *1 (S.D.N.Y. Aug. 9, 2018) (same). Moreover, while the conduct alleged in the Indictment may have occurred years ago, the risk of a significant term of incarceration – and thus the motive to flee – is of course only very recent.
Each of these factors – the seriousness of the allegations, the strength of the evidence, and the possibility of lengthy incarceration – creates an extraordinary incentive to flee. And as further described below, the defendant has the means and money to do so.
B. The Characteristics of the Defendant
The history and characteristics of the defendant also strongly support detention. As an initial matter, the defendant’s extensive international ties would make it exceptionally easy for her to flee and live abroad. The defendant was born in France and raised in the United Kingdom, where she attended school. Although she became a naturalized citizen of the United States in 2002, she also remains a citizen of the United Kingdom and France. Travel records from United States Customs and Border Protection (“CBP”) reflect that she has engaged in frequent international travel, including at least fifteen international flights in the last three years to locations including the United Kingdom, Japan, and Qatar. In addition, CBP records reflect that, consistent with her citizenship status, the defendant appears to possess passports from the United States, France, and the United Kingdom.
¹ Prior to the amendment, the statute of limitations for sexual offenses involving minors ran until the victim reached the age of 25, and as such, all of the relevant charges in the Indictment remained timely as of the 2003 amendment described above.
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DOJ-OGR-00001493
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