DOJ-OGR-00001912.jpg

ay Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 35 of 91 k7e2MaxC kjc relative of N Ww ws Oo OY ~] oO Ke) Ww a OY 20 21 22 23 24 25 associate. trust, relative and Once the det your Honor, in her motion Despite having put millions of dollars 35 Fendant and the other appears to be a close into this close associate, interview; said in its opening brief uncertain amount of wealth was s' the defendant not discuss this at all. before the and, in fact, desp tha the def court or in her Pretrial and despite its assets being controlled by a ndant mentions it not Services ite the fact that t the defendant's wealth, tored abroad, t's risk of Fligh defendant's whatsoever. no information about the det In sum, xtensiv finances and no ef your Honor, wealth. access to concealment, invitation that if to demand your Honor, we r further the court can't rely on this det transparent at this basic initial stage, on her to re earned Finally, proposed bail package, turn to court if the court's trust. your Honor, in light o ty including issues about There is no mention of the government finances and her whether her are serious concerns with respect to the defendant's opposition does the Fort to address those concerns the court has been given virtually Fendant's possession of and apparent The court should not take that espectfully submit, as an details, but released. all of Fendant instead to recognize the co In short, the red SOUTHERN D STR CT RE PORTERS, (212 ) 805-0300 to be urt cannot rely she has not turning to the defendant's flags here —- DOJ-OGR-00001912