{
  "document_metadata": {
    "page_number": "16",
    "document_number": "100",
    "date": "12/18/20",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 100 Filed 12/18/20 Page 16 of 36\n\nFrench law, is simply incorrect. Accordingly, the defendant's foreign ties, wealth, and skill at avoiding detection continue to weigh in favor of detention.\n\nFirst, there can be no serious dispute that the defendant has foreign ties. She is a citizen of three countries and holds three passports. As was already noted at the original hearing and is again evidenced in the Renewed Bail Application, the defendant has close relatives and friends who live abroad, as well as a multi-million dollar foreign property and at least one foreign bank account. (Tr. 83). In an attempt to minimize the defendant's foreign ties, the defense emphasizes the defendant's relatives and friends in the United States, history of residence in the United States, and United States citizenship. But the Court was already aware of those factors when making its original detention decision. (See Tr. 84; Dkt. 18 at 2, 12). The letters and documentation included in the Renewed Bail Motion simply prove points that were not in dispute. What that documentation does not do, however, is suggest that the defendant has the kind of ties to this country that come with any employment in the United States or any dependents living here.\n\nIndeed, as noted in the Pretrial Services Report, the defendant stated in July that she has no children and has no current employment. (Pretrial Services Report at 3).\n\nThe Renewed Bail Motion fails to establish sufficiently strong ties to the United States that would prevent her from fleeing. Although the defendant now claims her marriage would keep her in the United States, her motion does not address the plainly inconsistent statements she made to Pretrial Services at the time of her arrest, when, as documented in the Pretrial Services Report, the defendant said she was \"in the process of divorcing her husband.\" (Id.). On this point, it bears noting that the defendant's motion asks that she be permitted to live with _______ if granted bail, not her spouse. Moreover, the fact that the defendant's spouse has only now come forward to support the defendant should be afforded little weight given that he refused to come forward at the 13\n\nDOJ-OGR-00002177",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 100 Filed 12/18/20 Page 16 of 36",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "French law, is simply incorrect. Accordingly, the defendant's foreign ties, wealth, and skill at avoiding detection continue to weigh in favor of detention.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "First, there can be no serious dispute that the defendant has foreign ties. She is a citizen of three countries and holds three passports. As was already noted at the original hearing and is again evidenced in the Renewed Bail Application, the defendant has close relatives and friends who live abroad, as well as a multi-million dollar foreign property and at least one foreign bank account. (Tr. 83). In an attempt to minimize the defendant's foreign ties, the defense emphasizes the defendant's relatives and friends in the United States, history of residence in the United States, and United States citizenship. But the Court was already aware of those factors when making its original detention decision. (See Tr. 84; Dkt. 18 at 2, 12). The letters and documentation included in the Renewed Bail Motion simply prove points that were not in dispute. What that documentation does not do, however, is suggest that the defendant has the kind of ties to this country that come with any employment in the United States or any dependents living here.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Indeed, as noted in the Pretrial Services Report, the defendant stated in July that she has no children and has no current employment. (Pretrial Services Report at 3).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Renewed Bail Motion fails to establish sufficiently strong ties to the United States that would prevent her from fleeing. Although the defendant now claims her marriage would keep her in the United States, her motion does not address the plainly inconsistent statements she made to Pretrial Services at the time of her arrest, when, as documented in the Pretrial Services Report, the defendant said she was \"in the process of divorcing her husband.\" (Id.). On this point, it bears noting that the defendant's motion asks that she be permitted to live with _______ if granted bail, not her spouse. Moreover, the fact that the defendant's spouse has only now come forward to support the defendant should be afforded little weight given that he refused to come forward at the",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "13",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002177",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "defendant",
      "defendant's spouse",
      "defendant's husband"
    ],
    "organizations": [
      "Pretrial Services",
      "Court"
    ],
    "locations": [
      "United States"
    ],
    "dates": [
      "12/18/20",
      "July"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 100",
      "Tr. 83",
      "Tr. 84",
      "Dkt. 18",
      "Pretrial Services Report at 3",
      "DOJ-OGR-00002177"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a bail motion. The text is mostly printed, with no handwritten content. There are no visible stamps or signatures. The document is well-formatted and legible."
}