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CaGade2bter CD IZ0cdOhen Dete Gineh101 O20 2A |e 6.2730) 26a Geatgect J Ob 22 None of these conditions would reasonably assure the Defendant’s appearance. Here, too, the Court’s original determination applies with equal force. As the Court noted at the original hearing, the Defendant has demonstrated an extraordinary capacity to evade detection, “le|ven in the face of what the Defense has acknowledged to be extreme and unusual efforts to locate her.” Tr. at 87:4 87:19. Indeed, regardless of whether the Defendant sought to evade the press, rather than law enforcement, in the months leading up to her arrest, her sophistication in evading detection reveals the futility of relying on any conditions, including GPS monitoring, restrictive home confinement, and private security guards, to secure her appearance. See Tr. at 87:4 88:2. As other courts have observed, “home detention with electronic monitoring does not prevent flight; at best, it limits a fleeing defendant’s head start.” United States v. Zarger, No. 00- CR-773-S-1 (JG), 2000 WL 1134364, at *1 (E.D.N.Y. Aug. 4, 2000). Furthermore, while the Defendant now represents that she would be released to the custody of a family member, who would serve as the Defendant’s third-party custodian under 18 U.S.C. § 3142(c)(1)(B)(), and that she secured a residence in the Eastern District of New York, see Def. Mot. at 3, that does not outweigh the other significant factors weighing in favor of detention. And finally, the Defendant’s argument that private security guards could ensure her appearance at future proceedings runs afoul of the Bail Reform Act, which the Second Circuit has held “does not permit a two-tiered bail system in which defendants of lesser means are detained pending trial while wealthy defendants are released to self-funded private jails.” United States v. Boustani, 932 F.3d 79, 82 (2d Cir. 2019). As in Boustani, the Defendant in the present case would be detained regardless of her wealth, and “if a similarly situated defendant of lesser means would be detained, a wealthy defendant cannot avoid detention by relying on his personal funds to pay for private detention.” Jd. 19 DOJ-OGR-00001228