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ny Case 21-58, Document 39-2, 04/01/2021, 3068530, Page138 of 200 k7e2MaxC kjc it is clear that de NO Ww ws Oo OY ~] oO Ke} a oO he be No (ee) = Hs Oo _ OY a ~] a oO a Ke} 20 21 22 23 24 25 presumption of dete ntion in this case. the court to detain this det recommendation of P retrial Fendant, Services and the request of victims. It is imp ortant, this case, and defendant will i Thank you, your Honor. THE COURT: questions. Mr. the standards, carry Brief ly, that you have avoided the Cohen argued that you your Honor, Ms. Moe, failed the burdens under the statut the burden by a preponderance of fact of respect to risk of could assure appearance. suggested by Mr. Co MS. MOE: Standard is clear. hen Flight and whether in Do you disput terms of 715 fendant has not met her burden to rebut the The government urges consistent with that there be a just a couple of the the trial in the government has serious concerns that the afforded the opportunity. legal to address directly ther tory provision, and the government continuing to the evidence with measures that Your Honor, It CaSe »« is the det that could reasonably assure her con The government has the ultimat ar te anything legally the standard that applies? the government submits that the to rebut the presumption that there are no set of fendant's burden of te burden of production conditions tinued appearance in this persuasion, but it is the defendant's burden of production. She has failed to meet that burden for the reasons we set forth in our briefing and arguments today. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00019997