DOJ-OGR-00019959.pdf

Case 21-58, Document 39-2, 04/01/2021, 3068530, Page100 of 200 37 1 yet does not offer to post a single penny in security for the 2 bond she proposes. 3 Your Honor, the defendant is the very definition of a 4 flight risk. She has three passports, large sums of money, 5 extensive international connections, and absolutely no reason 6 to stay in the United States to face a potential significant 7 term of incarceration. 8 The government respectfully submits that the defendant 9 can't meet her burden of overcoming the statutory presumption 10 in favor of detention in this case. There are no conditions of 11 bail that would assure the defendant's presence in court 12 proceedings in this case, and we respectfully request that the 13 court detain the defendant pending trial. 14 Thank you, your Honor. 15 THE COURT: Thank you, Ms. Moe. 16 Just to make explicit what is clear by the 17 government's written presentation and oral presentation, you 18 are not resting your argument for detention on dangerousness to 19 the community at all. It is resting on risk of flight, 20 correct? 21 MS. MOE: That's correct, your Honor. 22 THE COURT: All right. Thank you. 23 Ms. Moe, you have indicated that you have heard from 24 victims who are entitled, under federal law, to be heard at 25 this proceeding. Could you indicate -- I think you indicated SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00019959