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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 20-2, 04/01/2021, 3068530, Page97 of 200 k7e2MaxC kjc phone, submit that in tinfoil except albeit as And then, the court noted, separately, t there could be no reason 34 the details about the cell are contained in our brief and we [ was discussing the defendant's for wrapping a cell phone for potentially to evade law enforcement, foolishly and not well executed. THE COURT: All right. Go ahead. MS. MOE: Thank you, your Honor. [ believe finances, which underscore the concern about the defendant's ability to The first is that reflecting to client information self-reported financial information there are concerns there flee and about her questionable candor to the court. for two reasons, we learned that records rel We submit your Honor. ating -- For a SWIFT bank include other words, disclosures made about the defendant's records, income is listed as ranging a mi are which are dat From the defendant. In when the account was opened, there were liion dollars. ted January 2019, from $200,000 to approximately half finances. In those the defendant's annual And both her net worth and liquid assets listed as ranging from $10 million and above. Second, as we noted in our reply, the defendant is the grantor of a trust account in the same SWIFT bank with assets of more than $4 million as of last month. Bank documents reflect that the trust has three trustees, one of whom has the authority to act independently. One of those trustees is a SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00001038