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Case 1:20-cr-00330-PAE Document 423 Filed 11/08/21 Page8of11 Page 8 presumption of detention, the presumption does not disappear; instead, it becomes a factor to be weighed and considered in deciding whether release is warranted. Jd. Where the Government seeks detention based on flight risk, the court must consider: (1) “the nature and circumstances of the offense charged”; (2) “the weight of the evidence against the person”; and (3) the “history and characteristics of the person.” 18 U.S.C. § 3142(g). A detention hearing may be reopened “at any time before trial if the judicial officer finds that information exists that was not known to the movant at the time of the hearing and that has a material bearing on the issue whether there are conditions of release that will reasonably assure the appearance of such person as required.” 18 U.S.C. § 3142(f); see also United States v. Bush, No. 18 Cr. 907 (PAC), 2021 WL 371782, at *1 (S.D.N.Y. Feb. 3, 2021) (motion for reconsideration of bail requires defendant to show “controlling decisions or data that the court overlooked— matters, in other words, that might reasonably be expected to alter the conclusion reached by the court” (internal citation and quotations omitted)). C. Discussion On three occasions, this Court has correctly found that there are no conditions of release that can reasonably assure the defendant’s appearance, given the grave risk of flight that she presents. In three carefully reasoned decisions issued after lengthy briefing and argument, this Court has concluded that detention is appropriate in light of the nature and circumstances of the offense, which carry a presumption of detention; the strength of the Government’s proffered evidence; and the defendant’s history and characteristics, particularly her substantial international ties, multiple foreign citizenships, familial and personal connections abroad, ownership of at least one foreign property of significant value, lack of candor about her finances, and “extraordinary capacity to evade detection.” (First Order at 79-91; Second Order at 7-20; Third Order at 6-11). DOJ-OGR- 00006208