DOJ-OGR-00020092.jpg
746 KB
Extraction Summary
3
People
3
Organizations
1
Locations
3
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal document
File Size:
746 KB
Summary
This legal document is a filing by the Government arguing for the continued detention of a defendant, asserting she is an extreme flight risk. The Government cites her foreign citizenship in a non-extraditing country, substantial international ties, financial resources, and a demonstrated sophistication in hiding assets. The filing also refutes the defendant's complaints about her conditions of confinement, stating she has ample access to her legal counsel and discovery materials.
People (3)
| Name | Role | Context |
|---|---|---|
| the defendant | Defendant |
The subject of the legal filing, whose detention is being argued for by the Government.
|
| Mercedes |
Cited in a legal case reference (Mercedes, 254 F.3d at 436) to support an argument.
|
|
| Epstein |
Cited in a legal case reference (Epstein, 425 F. Supp. 3d at 326) to support an argument.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Government | government agency |
The prosecuting party arguing for the defendant's detention.
|
| Court | government agency |
The judicial body that evaluates bail packages and made a prior finding regarding the defendant's flight risk.
|
| MDC | detention facility |
The facility where the defendant is being held, mentioned in the context of her conditions of confinement.
|
Timeline (3 events)
The original hearing where the seriousness of the offense and strength of evidence were identified.
Court
July
The initial bail hearing where the Court rejected the defendant's arguments about the potential harms of detention.
Court
Locations (1)
| Location | Context |
|---|---|
|
Mentioned in the first sentence, likely referring to the jurisdiction of the case.
|
Relationships (2)
The document states the defendant has time to communicate with her attorneys and has access to email and calls with defense counsel.
The Government is the prosecuting party arguing for the defendant's continued detention against her wishes.
Key Quotes (4)
"Each bail package in each case is considered and evaluated on its individual merits by the Court."Source
— Epstein, 425 F. Supp. 3d at 326
(Quoted from a previous case to establish the standard for evaluating bail applications.)
DOJ-OGR-00020092.jpg
Quote #1
"substantial international ties"Source
— Government (from transcript)
(A reason cited by the Government to argue that the defendant is a flight risk.)
DOJ-OGR-00020092.jpg
Quote #2
"familial and personal connections abroad"Source
— Government (from transcript)
(A reason cited by the Government to argue that the defendant is a flight risk.)
DOJ-OGR-00020092.jpg
Quote #3
"substantial financial resources"Source
— Government (from transcript)
(A reason cited by the Government to argue that the defendant is a flight risk.)
DOJ-OGR-00020092.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (2,175 characters)
Case 1:20-cr-560830-AJM Document 1002 Filed 02/18/20 Page 32 of 36
United States). Further, unlike those cases and the cases cited by the defendant, the crimes charged here involving minor victims trigger a statutory presumption in favor of detention, weighing further in favor of detention. See Mercedes, 254 F.3d at 436.
“Each bail package in each case is considered and evaluated on its individual merits by the Court.” Epstein, 425 F. Supp. 3d at 326. Unlike the cases cited by the defense, the Government seeks detention not solely on the basis that the defendant is of financial means and has foreign citizenship. Rather, detention is warranted because the defendant is a citizen of multiple foreign countries, including one that does not extradite its nationals, with “substantial international ties,” “familial and personal connections abroad,” and “substantial financial resources,” (Tr. 83-84), with a demonstrated sophistication in hiding herself and her assets, who, for the myriad reasons discussed herein and identified at the original hearing—including the seriousness of the offense, the strength of the Government’s evidence, and the potential length of sentence—presents a substantial flight risk. (Tr. 82-91). The defendant continues to pose an extreme risk of flight, and the defense has not offered any new information sufficient to justify reversal of the Court’s prior finding that no combination of conditions could ensure her appearance.
D. Conditions of Confinement
Finally, the Renewed Bail Application reiterates the same argument about the potential harms of detention on the defendant that this Court rejected at the initial bail hearing. (Tr. 42, 68-69). As was the case in July, these complaints do not warrant the defendant’s release.
The defendant continues to have more time than any other inmate at the MDC to review her discovery and as much, if not more, time to communicate with her attorneys. Specifically, the defendant currently has thirteen hours per day, seven days per week to review electronic discovery. Also during that time, the defendant has access to email with defense counsel, calls with defense
29
DOJ-OGR-00020092
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document