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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 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 32 of 91 32 k7e2MaxC kjc she passes. In other words, that she is widely known, was able to pass during the purchase of transaction under a fake name and not really can be no question that the deft that even though, that there is press as defense claims, verywhere, sh a real estate be detected. So there endant is willing to lie that she has the about who she is, means to do so. All of those concerning to the court, your Honor, whether the defendant has the ability off the grid indefinitely. A year is of time to live in hiding, undetected all of those things are concerning. she can live in hiding, things should be extremely as the court evaluates and willingness to live an extremely long period by the public. And so With respect to the question the government submits the court need issue, but we noted, your Honor, that the circumstances of there was a motive to evade detection the bigger picture, your Honor, THE COURT: Ms. Moe -- MS. MOE: GI —- ability -- THE COURT: —-- wasn't provided until the reply brief. that? MS. MOE: Yes, your Honor. make sure we had be very careful to the defendant's arrest that of motive, your Honor, not reach that ultimate there are indicia during suggested that by law enforcement. But is the defendant's -- I was surprised that that information Was there a reason for The government wanted to full and accurate SOUTHERN D STRICT REPORT BRS, Pes (212) 805-0300 DOJ-OGR-00001909