DOJ-OGR-00019915.jpg

CaGade2lepQO3GOsAuNnt Bie yuiPe/tl 220 2Ftil SO OF AL) 26a Geangiecl 2 Of 19 should raise concerns about the defendant’s access to financial resources that would enable her to flee. Moreover, and as set forth in the Detention Memorandum, the defendant has been associated with more than a dozen bank accounts from 2016 to the present, and during that period, the maximum total balances of those accounts have exceeded $20 million. Those accounts engaged in transfers in amounts of hundreds of thousands of dollars at a time, including as recently as 2019. To the extent the defendant now refuses to account for her ownership of or access to vast wealth, it is not because it does not exist — it is because she is attempting to hide it. The defendant’s proposal of ankle-bracelet monitoring should also be of no comfort to the Court. In particular, a GPS monitoring bracelet is of no persuasion because it is does nothing to prevent the defendant’s flight after it has been removed. At best, home confinement and electronic monitoring would reduce her head start should she decide to cut the bracelet and flee. See United States v. Banki, 10 Cr. 008 (JFK), Dkt. 7 (S.D.N.Y. Jan. 21, 2010) (denying bail to a naturalized citizen who was native to Iran, who was single and childless and who faced a statutory maximum of 20 years’ imprisonment, and noting that electronic monitoring is “hardly foolproof.’’), aff'd, 369 F. App’x 152 (2d Cir. 2010); United States v. Zarger, No. 00 Cr. 773, 2000 WL 1134364, at *1 (E.D.N.Y. Aug. 4, 2000) (rejecting defendant’s application for bail in part because home detention with electronic monitoring “at best . . . limits a fleeing defendant’s head start”); United States v. Benatar, No. 02 Cr. 099, 2002 WL 31410262, at *3 (E.D.N.Y. Oct. 10, 2002) (same). The defendant has no children in the United States, she does not reside with any immediate family members, and while the Government does not dispute that she is close with several of her siblings, as her time in hiding makes clear, she is clearly capable of maintaining those relationships remotely, which of course she could continue to do from abroad. Moreover, she has citizenship in 12 DOJ-OGR-00019915