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Case1:20-cr-00336-AJN Document 206 Filed 07/02/20 Page 9 of 20
(E.D.N.Y. Aug. 4, 2000) (Gleeson, J.) (rejecting defendant's application for bail in part because home detention with electronic monitoring "at best . . . limits a fleeing defendant's head start");
United States v. Benatar, No. 02 Cr. 099, 2002 WL 31410262, at *3 (E.D.N.Y. Oct. 10, 2002) (same); see also United States v. Casteneda, No. 18 Cr. 047, 2018 WL 888744, at *9 (N.D. Cal. Feb. 2018) (same); United States v. Anderson, 384 F. Supp. 2d 32, 41 (D.D.C. 2005) (same).
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 2, 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
9
DOJ-OGR-00000955