DOJ-OGR-00002246.jpg

Case 1:20-cr-00330-AJN Document106 Filed 12/30/20 Page 14 of 22 United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009), and United States v. Madoff, 586 F. Supp. 2d 240 (S.D.N.Y. 2009)). The Court’s concerns regarding the absence of any dependents, significant family ties, or employment in the United States, meanwhile, apply with somewhat less force in light of the evidence submitted in support of this motion. See id. at 84:4-84:9. The Defendant has submitted a litany of letters of support written by friends and family members. See Def. Mot., Exs. A-N, W-X. These letters, according to the Defendant, support her claim that she has significant ties to the United States and attest to the Defendant’s character. The Defendant places particular emphasis on the letter written by her spouse, whose identity and connection to the Defendant was withheld from the Court at the initial bail hearing. See Def. Mot. at 11-13. In that letter, her spouse expounds on the lives they led before her arrest, noting in particular that the Government’s characterization of the Defendant’s “transient” lifestyle, Dkt. No. 4 at 9, was belied by the “quiet family life” that they had enjoyed. Def. Mot. at 11; see also Def. Mot, Ex. A 4] 4-5. Other letters similarly highlight that the Defendant’s family and affective ties in the United States are stronger than was originally presented to the Court in the initial bail hearing. These letters substantiate the Defendant’s claim that she has important ties to people in the United States, but they leave unaltered the Court’s conclusion that flight would not pose an insurmountable burden for the Defendant. Among other things, the Defendant now argues that her newly revealed relationship with her spouse signals her deep affective ties in the country, but at the time she was arrested, she was not living with him and claimed to be getting divorced. See Pretrial Services Report at 3. Indeed, she does not propose to live with him were she to be released on bail, undercutting her argument that that relationship would create an insurmountable burden to her fleeing. Furthermore, the fact that she has friends and family in the United States 14 DOJ-OGR-00002246