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Case 1:20-cr-00330-AJN Document 165 Filed 03/09/21 Page 9 of 9 Page 9 determination that the Government’s case is strong. IV. Conclusion The defendant continues to represent a “plain[]” risk of flight. (Dec. Op. at 1). Even assuming the Court has jurisdiction to grant this third bail motion, the two new bail conditions offer insufficient protection against the “substantial and actual risk of flight” this Court has already found that the defendant poses. (/d. at 21). The defendant’s Third Bail Motion should be denied. Respectfully submitted, AUDREY STRAUSS United States Attorney By: __s/ Maurene Comey / Alison Moe / Lara Pomerantz Assistant United States Attorneys Southern District of New York Ce: All Counsel of Record (By email) DOJ-OGR-00002756