DOJ-OGR-00002250.jpg
Extracted Text (OCR)
Case 1:20-cr-00330-AJN Document 106 Filed 12/30/20 Page 18 of 22
millions of dollars and other assets that she could sell in order to support herself. See Gov’t
Opp’n at 23. Furthermore, the proposed bond is only partially secured. Taking into account the
vast amounts of wealth left relatively unrestrained by the bail package, that amount, standing
alone, cannot reasonably assure that she would appear before the Court. Nor is the Court’s
conclusion altered by the fact that a number of third parties have pledged to support her bond;
the amount of wealth that she would retain were she to flee, in addition to contingent assets and
future income streams that are not accounted for in the bail package, would plausibly enable her
to compensate them, in part or in full, for their losses. And while the Defendant argues that she
has procured “significant loans on the basis of a negative pledge” over a property and that $4
million is invested in an “illiquid hedge fund that could only be liquidated with considerable
difficulty,” see Def. Reply at 6, these arguments do not alter the Court’s ultimate conclusion
that the financial package does not meaningfully mitigate the possibility of flight.
The proposed conditions also provide that the Defendant would be released to the
custody of a family member, who would serve as the Defendant’s third-party custodian under 18
U.S.C. § 3142(c)(1)(B)(); that the Defendant would be placed in home confinement with GPS
monitoring and that her travel would be restricted to the Southern and Eastern Districts of New
York and would be limited to appearances in Court, meetings with counsel, medical visits, and
upon approval by the Court or Pretrial Services; that she would be under the strict supervision of
Pretrial Services; and that she would surrender all travel documents. /d. at 2-3. Furthermore,
the Defendant would have on-premises security guards who would prevent her from leaving the
residence at any time without prior approval by the Court or Pretrial Services and who would
escort her when she is authorized to leave. Jd. at 3.
18
DOJ-OGR-00002250
Extracted Information
Dates
Document Details
| Filename | DOJ-OGR-00002250.jpg |
| File Size | 710.6 KB |
| OCR Confidence | 94.6% |
| Has Readable Text | Yes |
| Text Length | 2,113 characters |
| Indexed | 2026-02-03 16:21:41.713395 |