DOJ-OGR-00019954.pdf

Case 21-58, Document 39-2, 04/01/2021, 3068530, Page95 of 200 32 she passes. In other words, even though, as defense claims, that she is widely known, that there is press everywhere, she was able to pass during the purchase of a real estate transaction under a fake name and not be detected. So there really can be no question that the defendant is willing to lie about who she is, that she can live in hiding, that she has the means to do so. All of those things should be extremely concerning to the court, your Honor, as the court evaluates whether the defendant has the ability and willingness to live off the grid indefinitely. A year is an extremely long period of time to live in hiding, undetected by the public. And so all of those things are concerning. With respect to the question of motive, your Honor, the government submits the court need not reach that ultimate issue, but we noted, your Honor, that there are indicia during the circumstances of the defendant's arrest that suggested that there was a motive to evade detection by law enforcement. But the bigger picture, your Honor, is the defendant's -- THE COURT: Ms. Moe -- MS. MOE: -- ability -- THE COURT: -- I was surprised that that information wasn't provided until the reply brief. Was there a reason for that? MS. MOE: Yes, your Honor. The government wanted to be very careful to make sure we had full and accurate SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00019954