Document 20-0770080

Case: 20-0770080 Document: 1-202 Filed: 03/23/21 Page: d21 of 518 EXHIBIT A DOJ-OGR-00001266 --- PAGE BREAK --- parallel those that the Court articulated when the Defendant proposed signing an extradition waiver. See Dec. Op. at 12–13. Similar doubts exist as to the Defendant’s offer to renounce her UK citizenship. The Court is persuaded by the Government’s arguments that even if the Defendant were to renounce her UK citizenship, she would still likely be able to delay or resist extradition from the UK. See Gov’t Opp’n at 6–7. And for largely similar reasons, the Court again concludes that the proposed conditions do not meaningfully diminish the Court’s concerns regarding the Defendant’s ability to flee and to frustrate or impair any subsequent extradition attempts. The possibility that the Defendant could successfully resist or forestall extradition heightens the Defendant’s incentive to flee. To summarize, the Defendant’s willingness to renounce her French and UK citizenship does not sufficiently assuage the Court’s concerns regarding the risk of flight that the Defendant poses. Considerable uncertainty regarding the enforceability and practical impact of the renunciations cloud whatever relevance they might otherwise have to the Court’s assessment of whether the Defendant poses a risk of flight. See United States v. Cohen, No. C 10-00547 (SI), 2010 WL 5387757, at *9 n.11 (N.D. Cal. Dec. 20, 2010). And that same uncertainty—and the possibility that she will be able to successfully resist, or at least delay, extradition—incentivizes flight, particularly because of the Defendant’s substantial international ties. Nor does the second proposed condition materially alter the Court’s determination that no condition or combination of conditions can reasonably assure the Defendant’s appearance. The Defendant proposes to have a retired federal judge provide oversight authority over her financial affairs, and, if granted, he would have the authority to restrain, monitor, and approve disbursement of assets requiring his signature. See Reply at 5. The Court continues to have 10 DOJ-OGR-00001283