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
Acting United States Attorney
Assistant United States Attorneys