DOJ-OGR-00019956.pdf

Case 21-58, Document 39-2, 04/01/2021, 3068530, Page97 of 200 34 1 And then, separately, the details about the cell phone, as the court noted, are contained in our brief and we submit that there could be no reason for wrapping a cell phone in tinfoil except for potentially to evade law enforcement, albeit foolishly and not well executed. 6 THE COURT: All right. Go ahead 7 MS. MOE: Thank you, your Honor. 8 I believe I was discussing the defendant's finances, which underscore the concern about the defendant's ability to flee and about her questionable candor to the court. We submit there are concerns there for two reasons, your Honor. 12 The first is that we learned that records relating -- reflecting to client information for a SWIFT bank include self-reported financial information from the defendant. In other words, when the account was opened, there were disclosures made about the defendant's finances. In those records, which are dated January 2019, the defendant's annual income is listed as ranging from $200,000 to approximately half a million dollars. And both her net worth and liquid assets are listed as ranging from $10 million and above. 21 Second, as we noted in our reply, the defendant is the grantor of a trust account in the same SWIFT bank with assets of more than $4 million as of last month. Bank documents reflect that the trust has three trustees, one of whom has the authority to act independently. One of those trustees is a SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00019956