court filing: Case 1:17-cr-00330-AJN Document 101002 Filed 02/13/20 Page 28 of 36

The document argues that the defendant's proposed bail package is insufficient because the assets backing it originated primarily from the defendant, not her spouse, and therefore would not provide a sufficient deterrent against flight. The government maintains that the defendant's financial resources, foreign ties, and ability to live in hiding support detention. The court filing references a relevant Second Circuit case, United States v. Boustani, in discussing the limitations of private bail conditions.