DOJ-OGR-00019957.pdf

Case 21-58, Document 39-2, 04/01/2021, 3068530, Page98 of 200 k7e2MaxC kjc 1 relative of the defendant and the other appears to be a close associate. 2 3 Despite having put millions of dollars into this trust, your Honor, and despite its assets being controlled by a relative and close associate, the defendant mentions it not once in her motion before the court or in her Pretrial Services interview; and, in fact, despite the fact that the government said in its opening brief that the defendant's finances and her uncertain amount of wealth, including issues about whether her wealth was stored abroad, are serious concerns with respect to the defendant's risk of flight, the defendant's opposition does not discuss this at all. There is no mention of the defendant's finances and no effort to address those concerns whatsoever. 4 5 In sum, your Honor, the court has been given virtually no information about the defendant's possession of and apparent access to extensive wealth. The court should not take that concealment, your Honor, we respectfully submit, as an invitation to demand further details, but instead to recognize that if the court can't rely on this defendant to be transparent at this basic initial stage, the court cannot rely on her to return to court if released. In short, she has not earned the court's trust. 6 7 Finally, your Honor, turning to the defendant's proposed bail package, in light of all of the red flags here -- SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00019957