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Case 1:20-cr-00330-PAE Document 423 Filed 11/08/21 Page9of11 Page 9 The defendant’s latest bail application does not meaningfully engage with the Court’s previous findings and reasoning. Nor does it identify any intervening change in law or factual circumstance. Instead, the defense turns to rhetoric and anecdotes better suited to tabloids than briefs. Where legal arguments can be found, they are cursory and unpersuasive. With respect to risk of flight, the defendant’s argument consists of a single paragraph, in which she asserts that she “is not a flight risk” because she “is a mature adult” who has “proclaimed her innocence” and therefore “[t]here is no indication that she would attempt to flee given her personality profile and determination to be exonerated.” (Def. Mot. 4). These conclusory assertions were also made in her prior bail applications, which have been rejected. (See, e.g., Dkt. 18 at 1, 3; Dkt. 97 at 1; Dkt. 160 at 2). And they completely fail to address the Court’s detailed findings about the defendant’s 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. The defendant’s primary argument consists of allegations and complaints about the conditions of her confinement, which are loosely tied to the claim that such conditions impair her ability to prepare for trial. But these same complaints have been a part of each of the defendant’s bail applications (see, e.g., Dkt. 18 at 7-9; Dkt. 97 at 35-38; Dkt. 171 at 9-10), as well as numerous other submissions to the Court. Throughout this case, the Court has maintained close oversight of those conditions, and ensured that the defendant has ample time to review her discovery and prepare for trial—more time, in fact, than any other inmate at the MDC. (Second Order at 20). And the Court has repeatedly found that the defendant’s ability to prepare for trial has not been ' For example, in response to the defendant’s most recent complaint—regarding the timing of her transportation to Court—the Court directed the Government to confer with the BOP and United States Marshals Service, and the Government is providing a letter addressing the issue today. DOJ-OGR-00006209