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Extracted Text (OCR)
Cased 20-D8-CO0GGOs7EIN 3HAcOMErit 20 2 il FO OF 202) 26a Ged Gect 2600
acts are so serious that both crimes carry a statutory presumption that no condition or combination
of conditions will reasonably assure the appearance of the defendant as required. 18 U.S.C. § 3142
(e)(3)(E). The defendant repeatedly engaged in this conduct, targeting girls as young as 14 years
old, for a period of years, and involving multiple minors.
These offenses carry significant penalties, and the defendant faces up to 35 years’
imprisonment if convicted. The possibility of a substantial sentence is a significant factor in
assessing the risk of flight. See United States v. Moscaritolo, No. 10 Cr. 4 (JL), 2010 WL 309679,
at *2 (D.N.H. Jan. 26, 2010) (“|The steeper the potential sentence, the more probable the flight
risk is, especially considering the strong case of the government . . . .”) (quoting United States v.
Alindato—Perez, 627 F. Supp. 2d 58, 66 (D.P.R. 2009)). Here, the defendant is facing a statutory
maximum of decades in prison. This fact alone would provide a compelling incentive for anyone
to flee from prosecution, but the incentive to flee is especially strong for this defendant, who, at
age 58, faces the very real prospect of spending a substantial portion of the rest of her life in prison.
The strength of the evidence in this case underscores the risk that the defendant will become
a fugitive. As the facts set forth in the Indictment make plain, the evidence in this case is strong.
Multiple victims have provided detailed, credible, and corroborated information against the
defendant. The victims are backed up contemporaneous documents, records, witness testimony,
and other evidence. For example, flight records, diary entries, business records, and other evidence
corroborate the victims’ account of events. This will be compelling evidence of guilt at any trial
in this case, which weighs heavily in favor of detention.
The passage of time between the defendant’s conduct and these charges does not counsel
otherwise. As an initial matter, all of the conduct is timely charged, pursuant to 18 U.S.C. § 3283,
which was amended in 2003 to extend the limitations period for conduct that was timely as of the
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Dates
Document Details
| Filename | DOJ-OGR-00019869.jpg |
| File Size | 530.4 KB |
| OCR Confidence | 94.1% |
| Has Readable Text | Yes |
| Text Length | 2,249 characters |
| Indexed | 2026-02-03 19:49:17.448312 |