Balance in bank accounts as indicated by the defendant.
This legal document is a memorandum from the Government arguing against the defendant's bail proposal. The Government asserts the defendant is a flight risk due to her considerable but undisclosed financial resources, her failure to submit a financial affidavit, and her history of lying under oath, specifically citing two counts of perjury from a 2016 civil suit. The document urges the Court to view the defendant as untrustworthy and deny the bail proposal, which it claims offers no security for her appearance.
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