The court filing includes an email from one of Holmes’ attorneys to the prosecution, claiming that the travel reservation was made before the verdict. In the email, Holmes’ attorney claims the former Theranos CEO hoped the verdict would be different and that she would be able to make this trip to attend the wedding of friends in Mexico.
It would surprise me that the terms of Holmes' bail permitted her to make plane reservations -- especially international plane reservations -- without the government's consent.* OTOH, the government did not say so in its opposition brief.
https://storage.courtlistener.com/recap ... 1721.0.pdf
The fact that the government hasn't previously brought the incident to the court's attention might suggest that it didn't think it was a big deal. Or, it could just mean that in January 2022 there was no tactical purpose to be served by bringing it up, as there is now, when Holmes is seeking to postpone her imprisonment until resolution of her appeal, which could be several years in the future.
Holmes is an unsympathetic convict. I hope that her motion is summarily denied.
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* It's routine for a defendant to be required to surrender her passport upon arraignment, and you can't fly to Mexico without one. So the entire episode is weird. However, google tells me that the market price of a fake passport is in the low four figures.