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Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 19 of 19 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 Oda os Alison Moe Alex Rossmiller Maurene Comey Assistant United States Attorneys (212) 637-2225 18 DOJ-OGR-00001629