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Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 28 of 91 k7e2MaxC kjc 28 1 In addition to the financial information described in 2 the government's memoranda, we note, your Honor, that in the 3 Pretrial Services report it appears that the defendant tried 4 initially to brush off the subject of her finances when th 5 Pretrial Services officer asked her, noting that she didn't 6 have those details. The defendant ultimately provided limited, 7 unverified, and questionable information that now appears in 8 the Pretrial Services report. She listed bank accounts 9 totaling less than a million dollars and a monthly income of 10 nothing. Zero dollars per month of income. 11 In addition to the matter of her finances, the report 12 raises other concerns about whether the defendant has been 13 fully transparent with the court or whether she is being 14 evasive. 15 THE COURT: Ms. Moe, you have emphasized the 16 indication on the financial report of zero dollars of the 17 income. Does the government think that there is income? Is 18 there some uncertainty as to whether that is investment income 19 as opposed to employment income or the like? What is the 20 reason for the emphasis on that or to the extent it is an 21 indication that the government finds that implausible? 22 MS. MOE: Yes, your Honor. 23 Separate from the matter of employment, it is very 24 unclear whether the defendant is receiving proceeds from trust 25 accounts or an inheritance or means of other kinds. It is SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00001905