DOJ-OGR-00001036.jpg

be N Ww ws Oo OY ~] oO Ke) a fan) = be N Ww = Hs Oo a OY a ~] a oO a Ke) 20 21 22 23 24 25 Case 21-770, Document k7e2MaxC kjc she passes. that she is widely known, was able to pass during the purchase of transaction under a In other words, fake name and not be detected. 20-2, 04/01/2021, 3068530, Page95 of 200 32 even though, as defense claims, that there is press verywhere, sh a real estate So there really can be no question that the defendant is willing to lie about who she is, that she can live in hiding, that she has the means to do so. All of those things should be extremely concerning to the court, your Honor, as the court evaluates whether the defendant has the ability and willingness to live off the grid indefinitely. A year is an extremely long period of time to live in hiding, undetected by the public. And so all of those things are concerning. With respect to the question of the government submits issue, the circumstances of but we noted, your Honor, motive, your Honor, the court need not reach that ultimate there was a motive to the bigger picture, THE COURT: Ms. MS. MOE: GI THE COURT: —- wasn't provided until the reply brief. that? MS. MOE: be very careful to your Honor, Yes, make sure we had that there are indicia during the defendant's arrest that suggested that vade detection by law enforcement. But is the defendant's -- Moe -- —- ability -- I was surprised that that information Was there a reason for your Honor. The government wanted to full and accurate SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00001036