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CONCLUSION
As set forth above, the defendant is an extreme risk of flight. The Government respectfully submits that the defendant cannot meet her burden of overcoming the statutory presumption in favor of detention. There are no conditions of bail that would assure the defendant's presence in court proceedings in this case. Accordingly, any application for bail should be denied.
Dated: New York, New York July 13, 2020
Respectfully submitted,
AUDREY STRAUSS
Acting United States Attorney
By: Alison G. Moe
Alison Moe
Alex Rossmiller
Maurene Comey
Assistant United States Attorneys
(212) 637-2225
18
DOJ-OGR-00001003