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Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 10 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 ofa 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.” 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 ? 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. DOJ-OGR-00001620