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Case 1:20-cr-00330-AJN Document 169 Filed 03/22/21 Page 8 of 12
that the Defendant poses a significant risk of flight. Thus, the Court again concludes that there
are no conditions of release that will reasonably assure her appearance in future proceedings.
B. Pretrial detention continues to be warranted
The thrust of the Defendant’s argument in her third motion for bail is that the two new
proposed conditions vitiate the Court’s concerns regarding the risk of flight. The Defendant first
offers to renounce her French and British citizenship. Def. Mot. at 2. And she also proposes to
have most of her and her spouse’s assets placed in a new account that will be monitored by a
retired federal judge, who would function as an asset monitor and will have co-signing authority
over the account. /d. Those conditions are offered in addition to the bail package she proposed
in December. See Dec. Op. at 16-17; see also Def. Mot. at 2. The new bail package does not
disturb the Court’s conclusion that the Government has carried its burden of showing that these
conditions are insufficient to mitigate the flight risks, and the Court again determines that no set
of conditions—including the two new ones—can reasonably assure her future appearance.
The Court begins with the Defendant’s offer to renounce her French and United Kingdom
citizenship. She notes that she can renounce her UK citizenship “immediately upon granting of
bail,” and she informs the Court that “[t]he process of renouncing her French citizenship, while
not immediate, may be expedited.” Def. Mot. at 4. As the Government notes, the offer is of
unclear validity, and the relevance and practical impact of the renunciations is, at best, unclear.
See Gov’t Opp’n at 5. With respect to her offer to renounce her French citizenship, the Court is
again confronted with dueling opinions on the correct interpretation of French law. The
Government relies on the position of the head of the International Criminal Assistance Bureau of
the French Ministry of Justice, who argues that “the fact that the wanted individual is a French
national constitutes an insuperable obstacle to his/her removal,” and that “[a]s long as said
DOJ-OGR-00002774
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| Filename | DOJ-OGR-00002774.jpg |
| File Size | 736.7 KB |
| OCR Confidence | 94.9% |
| Has Readable Text | Yes |
| Text Length | 2,211 characters |
| Indexed | 2026-02-03 16:27:01.591948 |