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Case 1:20-cr-00330-PAE Document 423 Filed 11/08/21 Page5of11 Page 5 (/d. at 16). The Court again concluded that the defendant presented a risk of flight and that the proposed bail package “cannot reasonably assure her appearance,” as it “would leave unrestrained millions of dollars and other assets that she could sell in order to support herself” and the “proposed bond is only partially secured.” (/d. at 16-18). Finally, the Court was “unpersuaded” by the defendant’s argument “that the conditions of her confinement are uniquely onerous, interfere with her ability to participate in her defense, and thus justify release.” (/d. at 20). The Court noted that the defendant did not “meaningfully dispute” that she has received more time than other inmates at the Metropolitan Detention Center (“MDC”) to review discovery and as much, if not more, time to communicate with her lawyers. (/d.). And the Court reiterated that it would continue to ensure that the defendant is able to speak and meet regularly with her attorneys and review discovery to prepare her defense. (/d. at 20 n.3). 3. The Court’s Third Detention Order On February 23, 2021, the defendant filed a third bail application, proposing two additional bail conditions: (1) renunciation of her French and British citizenship; and (2) placement of a portion of her and her spouse’s assets in a new account to be overseen by a monitor. (Dkt. 160). After considering multiple written submissions (Dkt. 160, 165, 171), the Court denied the defendant’s request in another written opinion. (Dkt. 169 (“Third Order’). The Court concluded that the defendant’s new application did not disturb its prior conclusions. (/d. at 2). The Court reiterated that detention was warranted in light of the proffered strength and nature of the Government’s case, the defendant’s “substantial international ties, familial and personal connections abroad, substantial financial resources, and experience evading detection,” and the defendant’s “lack of candor regarding her assets” at the time of her arrest. (/d. at 7). DOJ-OGR-00006205