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Case 21-770, Document 20-2, 04/01/2021, 3068530, Page91 of 200
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1 In addition to the financial information described in
2 the government's memoranda, we note, your Honor, that in the
3 Pretrial Services report it appears that the defendant tried
4 initially to brush off the subject of her finances when the
5 Pretrial Services officer asked her, noting that she didn't
6 have those details. The defendant ultimately provided limited,
7 unverified, and questionable information that now appears in
8 the Pretrial Services report. She listed bank accounts
9 totaling less than a million dollars and a monthly income of
10 nothing. Zero dollars per month of income.
11 In addition to the matter of her finances, the report
12 raises other concerns about whether the defendant has been
13 fully transparent with the court or whether she is being
14 evasive.
15 THE COURT: Ms. Moe, you have emphasized the
16 indication on the financial report of zero dollars of the
17 income. Does the government think that there is income? Is
18 there some uncertainty as to whether that is investment income
19 as opposed to employment income or the like? What is the
20 reason for the emphasis on that or to the extent it is an
21 indication that the government finds that implausible?
22 MS. MOE: Yes, your Honor.
23 Separate from the matter of employment, it is very
24 unclear whether the defendant is receiving proceeds from trust
25 accounts or an inheritance or means of other kinds. It is
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00001032