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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 34 of 91 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 which are dat From the defendant. In when the account was opened, there were ted January 2019, from $200,000 to approximately half finances. In those the defendant's annual a million dollars. And both her net worth and liquid assets are 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-00001911