DOJ-OGR-00019994.pdf

Case 21-58, Document 39-2, 04/01/2021, 3068530, Page135 of 200 1 Turning to several specific points, your Honor, that I 2 would like to respond to. I want to address the notion that 3 the defendant would have surrendered if the government had 4 asked her to. As defense counsel conceded, no offer along 5 those lines was ever made. And of course the government 6 doesn't have to accept the defense counsel's representation 7 that their client would surrender. 8 In fact, the fact that the government took these 9 measures to arrest the defendant reflects how seriously the 10 government takes the risk of the defendant of flight. Why on 11 earth would the government notify the defendant through her 12 counsel that she was about to be indicted and arrested if the 13 government had serious concerns that she was a risk of flight? 14 That is exactly what occurred here. 15 In addition, it is interesting that defense counsel 16 notes that it should have been obvious to the government that 17 the defendant would have surrendered when, at the same time, in 18 civil litigation in this district, defense counsel declined to 19 accept service on behalf of plaintiffs who were seeking to sue 20 the defendant in connection with some of these allegations, and 21 they were required to seek leave of the court to serve the 22 defendant through their counsel. 23 Your Honor, turning to the question of the defendant's 24 finances there is still at this point no substantive response 25 regarding defendant's finances or about the lack of candor to SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00019994