DOJ-OGR-00002185.jpg

Case 1:20-cr-00330-AJN Document 100 Filed 12/18/20 Page 24 of 36 the media even when a bounty was offered for her location and when numerous media outlets were searching for her. The charts, graphs, and affidavits proffered by the defense do not undercut the defendant’s skill at evading detection, and do nothing more than restate the justification for those actions that the defense already made at the prior hearing. (See Dkt. 18 at 14-16). That said, there is still reason to believe that the defendant was hiding not just from the press, but also from law enforcement. It is undisputed that defense counsel, even while in contact with the Government, never disclosed the defendant’s location or offered her surrender if she were to be charged. (Tr. 53-54). The Court already inquired about defense counsel’s interactions with the Government in the year leading up to the defendant’s arrest, and the Renewed Bail Application offers nothing new on that score. (/d.). Defense counsel contacted the Government when the FBI attempted to serve the defendant with a subpoena, but were unable to locate her, on July 7, 2019. Prior to her arrest, the Government and defense counsel communicated on multiple occasions between July and October of 2019, and communicated briefly on two additional occasions, most recently in March of 2020. At no point did defense counsel disclose the defendant’s location, offer to surrender the defendant, or offer to bring the defendant in to be interviewed. Moreover it is undisputed that when the FBI located the defendant, she ignored their directives and ran away from the arresting agents. Although the defense has submitted an affidavit from the defendant’s private security team, nothing in that affidavit should alter the Court’s determination that detention is appropriate here. The defense already informed the Court at the July 14, 2020 bail hearing that the defendant’s security protocol was to move to an inner room if her security was breached. (Tr. 55). Even still, the new affidavit makes clear that the agents who entered the defendant’s property were wearing clothing that clearly identified them as FBI agents. 21 DOJ-OGR-00002185