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be N Ww ws Oo OY ~] oO Ke) Ww a OY 20 21 22 23 24 25 Case 21-58, Document 39-2, 04/01/2021, 3068530, Page100 of 200 37 k7e2MaxC kjc yet does not offer to post a single penny in security for the bond she proposes. Your Honor, the defendant is the very definition of a xtensive international connections, to stay in the United States term of incarceration. The government resp flight risk. She has three passports, large sums of money, and absolutely no reason to face a potential significant ctfully submits that the defendant can't meet her burden of overcoming the statutory presumption in favor of detention in this case. bail that would assure the de proceedings in this case, and we respecti There are no conditions of fendant's presence in court court detain the defendant pending trial. Thank you, your Hono THE COURT: Thank yo Just to make explici government's written presenta are not resting your argument r. u, Ms. Moe. fully request that the t what is clear by the tion and oral presentation, you for detention on dangerousness to the community at all. It is resting on risk of flight, correct? MS. MOE: Ee] That's cor THE COURT: All righ rect, t. Thank you. your Honor. Ms. Moe, you have indicated that you have heard from victims who are entitled, under this proceeding. Could you indicate -- federal law, to be heard at think you indicated SOUTHERN DISTR CT RE PORT ERS, (212 ) 805-0300 P a Gs DOJ-OGR-00019959