DOJ-OGR-00001617.jpg
733 KB
Extraction Summary
2
People
4
Organizations
4
Locations
2
Events
1
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
733 KB
Summary
This legal document is a filing by the Government arguing against the defendant's motion to dismiss charges. The Government asserts that the charges are timely under the law, independent of a prior investigation, and that the defendant's claims are baseless. Furthermore, the document argues that the defendant poses an extreme flight risk due to her international ties, financial resources, and French citizenship, noting that France does not extradite its citizens to the U.S.
People (2)
| Name | Role | Context |
|---|---|---|
| The defendant | Defendant |
The subject of the legal filing, whose assertions are being refuted by the Government. She is described as a citizen ...
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| The victims | Victim |
Referenced in the Indictment. Two of them had not spoken to law enforcement until meeting with the prosecution's offi...
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Organizations (4)
| Name | Type | Context |
|---|---|---|
| The Government | Government agency |
The prosecuting party in the case, arguing against the defendant's claims and asserting she is a flight risk.
|
| SDFL | Government agency |
Mentioned in relation to a prior investigation that is described as independent from the current Indictment. Likely t...
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| The Court | Judicial body |
The judicial body being addressed in the filing, urged not to give weight to the defendant's assertions.
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| DOJ-OGR | Government agency |
Appears in the footer of the document as part of a document identifier (DOJ-OGR-00001617).
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Timeline (2 events)
2001-2007
A time period of conduct covered by a Non-Prosecution Agreement (NPA), which the Government states is separate from the conduct charged in the current Indictment.
2019
Two of the victims referenced in the Indictment met with the prosecution's office for the first time.
The victims
Our Office
Locations (4)
| Location | Context |
|---|---|
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The country of which the defendant is a citizen. It is noted that France does not extradite its citizens to the Unite...
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The country to which France does not extradite its citizens. The defendant is said to lack ties to the country.
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A location where the defendant is said to have no job or ties.
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The location where the current Indictment was brought, which is noted as being independent of the prior SDFL investig...
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Relationships (1)
The document is a legal filing by the Government arguing against the defendant's legal claims and seeking to establish her as a flight risk.
Key Quotes (2)
"legally flawed"Source
— The defendant
(The defendant's assertion that the indictment is flawed in unspecified ways, which the Government calls a 'bare assertion'.)
DOJ-OGR-00001617.jpg
Quote #1
"subject to dismissal"Source
— The defendant
(The defendant's assertion that the perjury counts should be dismissed for unspecified reasons, which the Government calls a 'conclusory claim'.)
DOJ-OGR-00001617.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (2,188 characters)
Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 7 of 19
charges conduct not covered by the NPA, which was limited by its terms to conduct spanning from 2001 to 2007, a time period that post-dates the conduct charged in the Indictment, and to violations of statutes not charged in this Indictment. In this respect, the Government further notes that the Indictment brought in this District is entirely independent of the prior SDFL investigation, and two of the victims referenced in the Indictment were never approached or interviewed by the SDFL, and had never spoken to law enforcement until they met with our Office in 2019.
Nor is there any force to the defendant’s assertion – without explanation, much less legal authority – that the charges in the Indictment are untimely. As the Government explained in its opening brief, the charges in this case are timely, pursuant to 18 U.S.C. § 3283, which permits the prosecution of crimes involving the sexual abuse of minors at any time during the life of the victim. The defendant’s claim that the Indictment is barred by the statute of limitations has no basis in law. For similar reasons, the Court should not give any weight to the defendant’s bare assertions that the indictment is somehow “legally flawed” in unspecified ways or that the perjury counts are “subject to dismissal” for unspecified reasons. Opposition Memorandum at 19. These conclusory claims are baseless.
III. The Defendant Poses An Extreme Risk of Flight
As the Government detailed in its opening brief, the defendant’s international ties, considerable financial resources, and transient lifestyle all make her a risk of flight. That risk is further exacerbated by the fact that the defendant is a citizen of France, which does not extradite its citizens to the United States pursuant to French law. In addition, and as detailed further below, the defendant has not only the motive to flee, but the means to do so swiftly and effectively. The defendant appears to have access to extensive sources of wealth. She does not have a job that would tie her to the United States, much less the Southern District of New York, and she does not
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DOJ-OGR-00001617
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