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Cased 20-CfQd3GO4AENt DHA Pre/Ntl ZZ) 2Fil SO OF ALG). 26a Geenfeo? 260.9 charges conduct not covered by the NPA, which was limited by its terms to conduct spanning from 2001 to 2007, a time period that post-dates the conduct charged in the Indictment, and to violations of statutes not charged in this Indictment. In this respect, the Government further notes that the Indictment brought in this District is entirely independent of the prior SDFL investigation, and two of the victims referenced in the Indictment were never approached or interviewed by the SDFL, and had never spoken to law enforcement until they met with our Office in 2019. Nor is there any force to the defendant’s assertion — without explanation, much less legal authority — that the charges in the Indictment are untimely. As the Government explained in its opening brief, the charges in this case are timely, pursuant to 18 U.S.C. § 3283, which permits the prosecution of crimes involving the sexual abuse of minors at any time during the life of the victim. The defendant’s claim that the Indictment is barred by the statute of limitations has no basis in law. For similar reasons, the Court should not give any weight to the defendant’s bare assertions that the indictment is somehow “legally flawed” in unspecified ways or that the perjury counts are “subject to dismissal” for unspecified reasons. Opposition Memorandum at 19. These conclusory claims are baseless. Ill. The Defendant Poses An Extreme Risk of Flight As the Government detailed in its opening brief, the defendant’s international ties, considerable financial resources, and transient lifestyle all make her a risk of flight. That risk is further exacerbated by the fact that the defendant is a citizen of France, which does not extradite its citizens to the United States pursuant to French law. In addition, and as detailed further below, the defendant has not only the motive to flee, but the means to do so swiftly and effectively. The defendant appears to have access to extensive sources of wealth. She does not have a job that would tie her to the United States, much less the Southern District of New York, and she does not DOJ-OGR-00000991