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736 KB
Extraction Summary
2
People
3
Organizations
1
Locations
3
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal document
File Size:
736 KB
Summary
This legal document is a filing by the Government arguing for the continued detention of the 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 the seriousness of the charges involving minor victims. The filing also refutes the defense's complaints about the conditions of confinement, stating the defendant has ample time and access to communicate with her counsel and review discovery materials.
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Government | Government agency |
The prosecuting party in the legal case, seeking the defendant's detention.
|
| Court | Judicial body |
The judicial body evaluating the bail package and detention arguments.
|
| MDC | Detention facility |
The facility where the defendant is being held ("inmate at the MDC").
|
Timeline (3 events)
The original hearing where the defendant's detention was discussed.
Court
Locations (1)
| Location | Context |
|---|---|
|
Mentioned in the first sentence of the main text.
|
Relationships (2)
The Government is the prosecuting party arguing for the defendant's continued detention against the wishes of the defendant and her defense.
defendant
→
Professional (Client-Attorney)
→
defense counsel/attorneys
The document mentions the defendant communicates with her attorneys and defense counsel, and the defense has filed applications on her behalf.
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 legal precedent to support the argument for individualized assessment of bail.)
DOJ-OGR-00002193.jpg
Quote #1
"substantial international ties"Source
— Transcript (Tr. 83-84)
(A reason cited by the Government for why the defendant is a flight risk.)
DOJ-OGR-00002193.jpg
Quote #2
"familial and personal connections abroad"Source
— Transcript (Tr. 83-84)
(A reason cited by the Government for why the defendant is a flight risk.)
DOJ-OGR-00002193.jpg
Quote #3
"substantial financial resources"Source
— Transcript (Tr. 83-84)
(A reason cited by the Government for why the defendant is a flight risk.)
DOJ-OGR-00002193.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (2,173 characters)
Case 1:20-cr-00330-AJN Document 100 Filed 12/18/20 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
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DOJ-OGR-00002193
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