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Cased 20-CfQd36O4AuNt Deeuere/ntl 2 0k ed OSPOZQ0P aja DO 2600 (E.D.N.Y. Aug. 4, 2000) (Gleeson, J.) (rejecting defendant’s application for bail in part because home detention with electronic monitoring “at best. . . limits a fleeing defendant’s head start’’); United States v. Benatar, No. 02 Cr. 099, 2002 WL 31410262, at *3 (E.D.N.Y. Oct. 10, 2002) (same); see also United States v. Casteneda, No. 18 Cr. 047, 2018 WL 888744, at *9 (N.D. Cal. Feb. 2018) (same); United States v. Anderson, 384 F. Supp. 2d 32, 41 (D.D.C. 2005) (same). CONCLUSION As set forth above, the defendant is an extreme risk of flight. The Government respectfully submits that the defendant cannot meet her burden of overcoming the statutory presumption in favor of detention. There are no conditions of bail that would assure the defendant’s presence in court proceedings in this case. Accordingly, any application for bail should be denied. Dated: New York, New York July 2, 2020 Respectfully submitted, AUDREY STRAUSS Acting United States Attorney Alison Moe Alex Rossmiller Maurene Comey Assistant United States Attorneys (212) 637-2225 By: DOJ-OGR-00000955