DOJ-OGR-00019945.pdf

Case 21-58, Document 39-2, 04/01/2021, 3068530, Page86 of 200 23 1 hearing from the government first, and then any alleged victims 2 who have indicated that they wish to be heard pursuant to 18 3 U.S.C. 3771(a)(4), and then I will hear from Mr. Cohen. 4 Any objection to proceeding thusly, Mr. Cohen? 5 MR. COHEN: No, your Honor. 6 THE COURT: Ms. Moe. 7 MS. MOE: Thank you, your Honor. 8 Your Honor, as we set forth in our moving papers, the 9 government strongly believes that this defendant poses an 10 extreme risk of flight. Pretrial Services has recommended 11 detention, the victims seek detention, and the government 12 respectfully submits that the defendant should be detained 13 pending trial. 14 Your Honor, there are serious red flags here. The 15 defendant has significant financial means. It appears that she 16 has been less than candid with Pretrial Services. She has not 17 come close to thoroughly disclosing her finances to the court. 18 She has strong international ties and appears to have the 19 ability to live beyond the reach of extradition. She has few, 20 if any, community ties, much less a stable residence that she 21 can propose to the court to be bailed to. And she has a strong 22 incentive to flee to avoid being held accountable for her 23 crimes. 24 Because the defendant is charged with serious offenses 25 involving the sexual abuse of minors, your Honor, there is a SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00019945