DOJ-OGR-00002177(1).jpg

742 KB

Extraction Summary

2
People
2
Organizations
1
Locations
2
Events
1
Relationships
1
Quotes

Document Information

Type: Legal document
File Size: 742 KB
Summary

This legal document is a court filing arguing against granting bail to a defendant. The prosecution contends that the defendant is a significant flight risk due to her extensive foreign ties, including citizenship in three countries, foreign property, and bank accounts. The filing also highlights her weak ties to the United States and points out inconsistencies in her statements, such as previously claiming to be divorcing the same husband she now cites as a reason to remain in the country.

People (2)

Name Role Context
defendant defendant
The subject of the legal filing, argued to be a flight risk due to foreign ties, wealth, and inconsistent statements.
defendant's spouse spouse
Mentioned in relation to the defendant's marital status and ties to the U.S. The defendant claimed to be divorcing hi...

Organizations (2)

Name Type Context
Pretrial Services government agency
An agency to which the defendant made statements, which are documented in the Pretrial Services Report.
Court government agency
The judicial body that made the original detention decision and is considering the Renewed Bail Motion.

Timeline (2 events)

The original hearing where the defendant's detention was decided.
United States
The defendant was arrested, at which time she made a statement to Pretrial Services about her marriage.
United States

Locations (1)

Location Context
The country where the legal proceedings are taking place and where the defendant's ties are being evaluated.

Relationships (1)

defendant marital defendant's spouse
The document states they are spouses, but the defendant previously claimed she was 'in the process of divorcing her husband.' The spouse has now come forward to support the defendant's bail application.

Key Quotes (1)

"in the process of divorcing her husband."
Source
— defendant (A statement made by the defendant to Pretrial Services at the time of her arrest, which is cited as inconsistent with her current claim that her marriage would keep her in the U.S.)
DOJ-OGR-00002177(1).jpg
Quote #1

Full Extracted Text

Complete text extracted from the document (2,243 characters)

Case 1:20-cr-00330-AJN Document 100 Filed 12/18/20 Page 16 of 36
French law, is simply incorrect. Accordingly, the defendant’s foreign ties, wealth, and skill at avoiding detection continue to weigh in favor of detention.
First, there can be no serious dispute that the defendant has foreign ties. She is a citizen of three countries and holds three passports. As was already noted at the original hearing and is again evidenced in the Renewed Bail Application, the defendant has close relatives and friends who live abroad, as well as a multi-million dollar foreign property and at least one foreign bank account. (Tr. 83). In an attempt to minimize the defendant’s foreign ties, the defense emphasizes the defendant’s relatives and friends in the United States, history of residence in the United States, and United States citizenship. But the Court was already aware of those factors when making its original detention decision. (See Tr. 84; Dkt. 18 at 2, 12). The letters and documentation included in the Renewed Bail Motion simply prove points that were not in dispute. What that documentation does not do, however, is suggest that the defendant has the kind of ties to this country that come with any employment in the United States or any dependents living here. Indeed, as noted in the Pretrial Services Report, the defendant stated in July that she has no children and has no current employment. (Pretrial Services Report at 3).
The Renewed Bail Motion fails to establish sufficiently strong ties to the United States that would prevent her from fleeing. Although the defendant now claims her marriage would keep her in the United States, her motion does not address the plainly inconsistent statements she made to Pretrial Services at the time of her arrest, when, as documented in the Pretrial Services Report, the defendant said she was “in the process of divorcing her husband.” (Id.). On this point, it bears noting that the defendant’s motion asks that she be permitted to live with [REDACTED] if granted bail, not her spouse. Moreover, the fact that the defendant’s spouse has only now come forward to support the defendant should be afforded little weight given that he refused to come forward at the
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DOJ-OGR-00002177

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