DOJ-OGR-00002197.jpg

Case 1:20-cr-00330-AJN Document 100 Filed 12/18/20 Page 36 of 36 CONCLUSION As this Court previously found, the defendant “poses a substantial actual risk of flight.” (Tr. 86). Nothing in the defense submission justifies altering the Court’s prior conclusion that there are no conditions of bail that would assure the defendant’s presence in court proceedings in this case. Accordingly, the Renewed Bail Motion should be denied. Dated: New York, New York December 16, 2020 By: Respectfully submitted, AUDREY STRAUSS Acting United States Attorney Maurene Comey Alison Moe Lara Pomerantz Assistant United States Attorneys (212) 637-2324 33 DOJ-OGR-00002197