DOJ-OGR-00000994.jpg

539 KB

Extraction Summary

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People
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Organizations
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Locations
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Events
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Relationships
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Quotes

Document Information

Type: Legal document
File Size: 539 KB
Summary

This legal document is a portion of a filing by the Government arguing against granting bail to the defendant. The prosecution contends that the defendant is a significant flight risk due to her considerable but undisclosed financial resources and her history of dishonesty, including alleged perjury in a 2016 civil suit. The document criticizes the defendant's bail proposal for offering no security and for her failure to submit a financial affidavit, which prevents the Court from assessing her true ability to flee.

People (1)

Name Role Context
the defendant defendant
The subject of the legal filing, accused of criminal actions, perjury, and being a flight risk. Her bail proposal is ...

Organizations (3)

Name Type Context
The Government government agency
The prosecuting party in the case, arguing against the defendant's bail proposal and highlighting her as a flight risk.
The Court judicial body
The entity that will decide on the defendant's bail. The document argues the Court should be concerned about the defe...
Pretrial Services government agency
Mentioned in a footnote as the source of information that the defendant has indicated she has less than a million dol...

Timeline (3 events)

2016
In the context of a civil suit, the defendant allegedly lied repeatedly about her conduct with minors, leading to two counts of perjury.
The defendant's application for bail, during which she allegedly failed to fill out a financial affidavit.
The defendant's arrest in the current case.

Locations (1)

Location Context
Mentioned in the context of the defendant's assets, which she has not disclosed whether they are in the United States...

Relationships (1)

the defendant adversarial (legal) The Government
The document is a legal filing by the Government arguing against the defendant's bail proposal, portraying her as untrustworthy and a flight risk.

Full Extracted Text

Complete text extracted from the document (2,238 characters)

Case: 20-07003-AJN Document 120 Filed 07/13/20 Page 9 of 19
spent the last two decades without facing consequences for her criminal actions. For years before her arrest in this case, the defendant likely believed she had gotten away with her crimes. That illusion has now been shattered, and she has a host of new reasons to use her considerable resources to flee.
Moreover, the defendant’s willingness to brazenly lie under oath about her conduct, including some of the conduct charged in the Indictment, strongly suggests her true motive has been and remains to avoid being held accountable for her crimes, rather than to avoid the media. As alleged in the Indictment, in 2016, when the defendant was given the opportunity to address her conduct with minors in the context of a civil suit, she lied repeatedly. Those lies are, of course, the subject of two counts of perjury, and they evidence her willingness to flout the law in order to protect herself. The defendant’s lies under oath should give the Court serious pause about trusting this defendant to comply with conditions of bail.
IV. The Defendant’s Bail Proposal Offers No Security For Her Appearance
In its opening memorandum, the Government highlighted the defendant’s extensive means to flee and her opaque finances. In her response, the defendant’s brief provides zero information about her assets in the United States or abroad. The Court should be troubled by this. First, so far as the Government is aware, the defendant has not filled out a financial affidavit, under penalty of perjury, in connection with her application for bail, meaning that the Court has no reliable insight into the magnitude or scope of the defendant’s resources.² However, what the Court does have are strong indicia that the defendant has access to enormous resources, including the large property she was found on, the private security guard being retained to live with her on that
² The Government understands from Pretrial Services that the defendant has indicated that she has less than a million dollars in bank accounts. The report has not yet been released. As discussed below, the Court should have serious pause before accepting this unverified information.
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DOJ-OGR-00000994

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