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Page 9 of the indictment memo

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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,


Acting United States Attorney


Alison Moe

Alex Rossmiller

Maurene Comey

Assistant United States Attorneys

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Page 9 of the indictment memo