DOJ-OGR-00019870.jpg

Cased 20-D8-CO0GGOs7EIN 3HAcOErit 20 2 | GO OF A092 26agedgeor 2600 date of the amendment,! to permit a prosecution at any point during the lifetime of the minor victim. See United States v. Chief, 438 F.3d 920, 922-25 (9th Cir. 2006) (finding that because Congress extended the statute of limitations for sex offenses involving minors during the time the previous statute was still running, the extension was permissible); United States v. Pierre-Louis, No. 16 Cr. 541 (CM), 2018 WL 4043140, at *1 (S.D.N.Y. Aug. 9, 2018) (same). Moreover, while the conduct alleged in the Indictment may have occurred years ago, the risk of a significant term of incarceration — and thus the motive to flee — is of course only very recent. Each of these factors — the seriousness of the allegations, the strength of the evidence, and the possibility of lengthy incarceration — creates an extraordinary incentive to flee. And as further described below, the defendant has the means and money to do so. B. The Characteristics of the Defendant The history and characteristics of the defendant also strongly support detention. As an initial matter, the defendant’s extensive international ties would make it exceptionally easy for her to flee and live abroad. The defendant was born in France and raised in the United Kingdom, where she attended school. Although she became a naturalized citizen of the United States in 2002, she also remains a citizen of the United Kingdom and France. Travel records from United States Customs and Border Protection (“CBP”) reflect that she has engaged in frequent international travel, including at least fifteen international flights in the last three years to locations including the United Kingdom, Japan, and Qatar. In addition, CBP records reflect that, consistent with her citizenship status, the defendant appears to possess passports from the United States, France, and the United Kingdom. ' Prior to the amendment, the statute of limitations for sexual offenses involving minors ran until the victim reached the age of 25, and as such, all of the relevant charges in the Indictment remained timely as of the 2003 amendment described above. DOJ-OGR-00019870