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    "date": "12/10/20",
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  "full_text": "Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 32 of 91 32 k7e2MaxC kjc 1 she passes. In other words, even though, as defense claims, 2 that she is widely known, that there is press everywhere, she 3 was able to pass during the purchase of a real estate 4 transaction under a fake name and not be detected. So there 5 really can be no question that the defendant is willing to lie 6 about who she is, that she can live in hiding, that she has the 7 means to do so. All of those things should be extremely 8 concerning to the court, your Honor, as the court evaluates 9 whether the defendant has the ability and willingness to live 10 off the grid indefinitely. A year is an extremely long period 11 of time to live in hiding, undetected by the public. And so 12 all of those things are concerning. 13 With respect to the question of motive, your Honor, 14 the government submits the court need not reach that ultimate 15 issue, but we noted, your Honor, that there are indicia during 16 the circumstances of the defendant's arrest that suggested that 17 there was a motive to evade detection by law enforcement. But 18 the bigger picture, your Honor, is the defendant's -- 19 THE COURT: Ms. Moe -- 20 MS. MOE: -- ability -- 21 THE COURT: -- I was surprised that that information 22 wasn't provided until the reply brief. Was there a reason for 23 that? 24 MS. MOE: Yes, your Honor. The government wanted to 25 be very careful to make sure we had full and accurate SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00001909",
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      "content": "1 she passes. In other words, even though, as defense claims, 2 that she is widely known, that there is press everywhere, she 3 was able to pass during the purchase of a real estate 4 transaction under a fake name and not be detected. So there 5 really can be no question that the defendant is willing to lie 6 about who she is, that she can live in hiding, that she has the 7 means to do so. All of those things should be extremely 8 concerning to the court, your Honor, as the court evaluates 9 whether the defendant has the ability and willingness to live 10 off the grid indefinitely. A year is an extremely long period 11 of time to live in hiding, undetected by the public. And so 12 all of those things are concerning. 13 With respect to the question of motive, your Honor, 14 the government submits the court need not reach that ultimate 15 issue, but we noted, your Honor, that there are indicia during 16 the circumstances of the defendant's arrest that suggested that 17 there was a motive to evade detection by law enforcement. But 18 the bigger picture, your Honor, is the defendant's -- 19 THE COURT: Ms. Moe -- 20 MS. MOE: -- ability -- 21 THE COURT: -- I was surprised that that information 22 wasn't provided until the reply brief. Was there a reason for 23 that? 24 MS. MOE: Yes, your Honor. The government wanted to 25 be very careful to make sure we had full and accurate",
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