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Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 11 of 19 property, and the multi-million dollar property in the United Kingdom being offered as collateral. Indeed, it is revealing that the defendant’s memorandum declines to discuss her assets or the assets to which she plainly has access. Without knowing the full scope of the defendant’s financial resources, it would be impossible for the Court to even begin to evaluate whether conditions of bail would mitigate her risk of flight. More importantly, the defendant cannot claim that she has met her significant burden to rebut the presumption of detention in this case when she has failed to provide comprehensive, verified financial information under penalty of perjury. Although the Government submits that no conditions of bail could reasonably assure the defendant’s continued appearance, the defendant’s proposed bail package offers almost no security whatsoever. The defendant appears to have significant assets, she has extensive foreign ties and is a citizen of a country that does not extradite its citizens to the United States, and she is charged with serious crimes involving the sexual exploitation of minors — and yet, she asks the Court to grant her bail secured only by a foreign property, which provides effectively no security at all. Indeed, it is curious that a defendant who appears to have access to millions of dollars has not offered to post a single dime as collateral for the bond she proposes. Instead, as noted, she offers as security a foreign property, which is effectively meaningless. As a practical matter, the Government has no direct way to proceed against foreign property or sureties through bail forfeiture, because the Government cannot seize a foreign citizen’s assets abroad or sell property in another nation based on a United States bail forfeiture judgment. The Government would be required to attempt to litigate a property dispute in another country, with a lengthy process and an uncertain outcome. Additionally, the defendant proffers no information about her proposed co-signers other than that they are friends and relatives — in particular, she provides no information about the assets 10 DOJ-OGR-00001621