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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 36 of 91 36 k7e2MaxC kjc the defendant's demonstrated willingness and ability to live in hiding, her ability to live comfortably beyond the reach of extradition, her strong interactional ties and lack of community ties, significant and unexplained wealth, and the presumption of detention in light of very serious charges -- in light of the defendant all that, your Honor, it is extremely surprising that would propose a bail package with virtually no security whatsoever. absence of makes no mention whatsoever about the Or assets 01 provide to Pr etrial In addition to proposed cosigners of fF her spouse whose her iden Services. financial failing to describe in any way the a bond, the defendant also circumstances tity she declined to There is no information about who will be cosigning this bond or their assets and no details whatsoever. would be that the verified The government submits that no conditions of appropriate here. But it is revealing, bail your Honor, fF her accounting o% defendant had both declined to provide a rigorous, finances and that she does not propose that she pledge any meaningful security for her release. She identifies no stable residence where she could reside. Instead, she proposes, among other proposals, that she stay at a luxury hotel in Manhattan, the most transient type of residence. And it is curious, your Honor, that the defendant offers to pay for a luxury hotel for an indefinite period and SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00001913