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Case 1:20-cr-00330-AJN Document 165 Filed 03/09/21 Page 4 of 9 Page 4 are serious and carry lengthy terms of imprisonment if convicted; the evidence proffered by the Government, including multiple corroborating and corroborated witnesses, is strong; the Defendant has substantial resources and foreign ties (including citizenship in a country that does not extradite its citizens); and the Defendant, who lived in hiding and apart from the family to whom she now asserts important ties, has not been fully candid about her financial situation.” (Dec. Op. at 2). In seeking bail for a third time, the defendant’s Motion rests principally on two additional bail conditions. Neither of these conditions will reasonably assure the defendant’s appearance in court, and neither outweighs all of the other factors that make this defendant an extreme flight risk. Moreover, the Court should reject as premature the defendant’s assertion that her pretrial motions have somehow weakened the Government’s case; those motions have not been adjudicated, and, for the reasons set forth in the Government’s opposition memorandum, the defendant’s motions have no merit. In short, all three of the relevant Bail Reform Act factors—the nature and circumstances of the offense, the strength of the evidence, and the history and characteristics of the defendant— continue to weigh heavily in favor of detention, and the defendant’s Motion does not present any information that warrants revisiting this Court’s well-reasoned and detailed prior decisions. A. Applicable Law “After a court has made an initial determination that no conditions of release can reasonably assure the appearance of the Defendant as required, the Court may reopen the bail hearing if ‘information exists that was not known to the movant at the time of the hearing and that has a material bearing on the issue’ of whether pretrial detention is warranted.” (Dec. Op. at 4 (quoting 18 U.S.C. § 3142(f)). “A court may also revisit its own decision pursuant to its inherent authority, even where the circumstances do not match § 3142(f)’s statutory text.” (Ud. at 5). Although courts in this Circuit have recognized that “‘a release order may be reconsidered even where the evidence proffered on reconsideration was known to the movant at the time of the original hearing,” United States v. Rowe, No. 02 Cr. 756 (LMM), 2003 WL 21196846, at *1 (S.D.N.Y. May 21, 2003), generally the moving party must establish that its arguments “warrant reconsideration” by, for example, demonstrating “that the court overlooked information or incorrectly applied the law,” or that failure to reconsider “would constitute manifest injustice.” United States v. Petrov, No. 15 Cr. 66 (LTS), 2015 WL 11022886, at *3 (S.D.N.Y. Mar. 26, 2015). B. Discussion The defendant’s Motion rests on three arguments, none of which is availing. First, the defendant offers to renounce her foreign citizenship, claiming that this eliminates the risk that she will flee from prosecution. Second, the defendant offers to place some of her assets in a monitorship with unspecified terms, and which would still leave her with substantial unrestrained assets. Third, the defendant claims that her voluminous pretrial motions have diminished the strength of the Government’s case. None of these arguments is persuasive, and the Motion should be denied. DOJ-OGR-00002751