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Case 1:20-cr-00330-PAE Document 423 Filed 11/08/21 Page3of11 Page 3 concluded that electronic monitoring and private security guards “would be insufficient” because the defendant could remove the monitor and evade private guards. (/d. at 87-88). Finally, the Court rejected the defendant’s arguments about the risks of COVID-19 and the difficulty of preparing a defense with an incarcerated client, noting that the defendant had many months to prepare for trial. (/d. at 89-90). The Court found that measures in place were sufficient to ensure the defendant’s access to her counsel, but also directed the Government to work with the defense “to provide adequate communication between counsel and client” and stated that the defense may make specific applications to the Court for further relief if the process was “inadequate in any way.” (/d. at 90-91). 2. The Court’s Second Detention Order The defendant renewed her bail application in December 2020, presenting a revised bail package with additional financial restrictions. (Dkt. 97). After receiving further written submissions (Dkt. 100, 103), the Court denied the defendant’s application in a written opinion issued on December 28, 2020. (Dkt. 106 (“Second Order”)). The Court found that the arguments presented “either were made at the initial bail hearing or could have been made then” and the new information “only solidifies the Court’s view that the Defendant plainly poses a risk of flight and that no combination of conditions can ensure her appearance.” (/d. at 1-2). The Court explained: the charges, which carry a presumption of detention, 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. (Id. at 2). The Court rejected the defendant’s claim that the Government overstated the strength of its case at the bail hearing, finding that the defendant “too easily discredits the witness testimony.” DOJ-OGR-00006203