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Extracted Text (OCR)
Case 1:20-cr-00330-AJN Document 100 Filed 12/18/20 Page 16 of 36
French law, is simply incorrect. Accordingly, the defendant’s foreign ties, wealth, and skill at
avoiding detection continue to weigh in favor of detention.
First, there can be no serious dispute that the defendant has foreign ties. She is a citizen
of three countries and holds three passports. As was already noted at the original hearing and is
again evidenced in the Renewed Bail Application, the defendant has close relatives and friends
who live abroad, as well as a multi-million dollar foreign property and at least one foreign bank
account. (Tr. 83). In an attempt to minimize the defendant’s foreign ties, the defense emphasizes
the defendant’s relatives and friends in the United States, history of residence in the United States,
and United States citizenship. But the Court was already aware of those factors when making its
original detention decision. (See Tr. 84; Dkt. 18 at 2, 12). The letters and documentation included
in the Renewed Bail Motion simply prove points that were not in dispute. What that
documentation does not do, however, is suggest that the defendant has the kind of ties to this
country that come with any employment in the United States or any dependents living here.
Indeed, as noted in the Pretrial Services Report, the defendant stated in July that she has no children
and has no current employment. (Pretrial Services Report at 3).
The Renewed Bail Motion fails to establish sufficiently strong ties to the United States that
would prevent her from fleeing. Although the defendant now claims her marriage would keep her
in the United States, her motion does not address the plainly inconsistent statements she made to
Pretrial Services at the time of her arrest, when, as documented in the Pretrial Services Report, the
defendant said she was “in the process of divorcing her husband.” (/d.). On this point, it bears
noting that the defendant’s motion asks that she be permitted to live with i if granted bail,
not her spouse. Moreover, the fact that the defendant’s spouse has only now come forward to
support the defendant should be afforded little weight given that he refused to come forward at the
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DOJ-OGR-00002177
Extracted Information
Dates
Document Details
| Filename | DOJ-OGR-00002177.jpg |
| File Size | 742.3 KB |
| OCR Confidence | 95.1% |
| Has Readable Text | Yes |
| Text Length | 2,235 characters |
| Indexed | 2026-02-03 16:20:51.670712 |