DOJ-OGR-00002238(1).pdf

--- Page 1 --- **Document Image Extraction** **Case Information:** * Case Number: 1:20-cr-00330-AJN * Document Number: Document 106 * Filed Date: 12/30/20 **Page Information:** * Page Number: 6 of 22 **Text Extraction:** **Header:** Case 1:20-cr-00330-AJN Document 106 Filed 12/30/20 Page 6 of 22 **Text Body:** counsel, medical visits, and upon approval by the Court or Pretrial Services. Id. at 2–3. Furthermore, the Defendant would have on-premises security guards that she would pay for who would prevent her from leaving the residence at any time without prior approval by the Court or Pretrial Services and who would escort her when she is authorized to leave. Id. at 3. The motion also presents new information that, according to the Defendant, addresses the concerns that the Court articulated when it determined that detention was warranted. This newly presented information, most of which was available to the Defendant at the time of the initial bail hearing, includes evidence of the Defendant's family ties in the United States, see Def. Mot. at 10–14; a detailed financial report that provides a more comprehensive outlook on the Defendant's financial conditions and assets, see id. at 15–18; evidence that according to her rebuts the Government's original contention that she attempted to evade law enforcement prior to her arrest, see id. at 18–25; waivers of her right to contest extradition from the United Kingdom and France, along with expert opinions claiming that the Defendant would not be able to resist extradition if she were to execute the waivers, see id. at 25–29; and evidence that she argues lays bare the weakness of the Government's case against her, see id. at 30–34. Finally, the Defendant argues that the conditions of her confinement, including as a result of the COVID-19 pandemic, present an additional factor favoring release. She claims that the conditions imposed are punitive and that those conditions interfere with her ability to participate in her defense, and she asserts that these factors further militate in favor of release. See id. at 34–38. Having carefully considered all of the Defendant's arguments, the Court again concludes that no conditions or combination of conditions could reasonably assure her appearance and that **Footer:** DOJ-OGR-00002238 **Note:** The image appears to be a page from a legal document, likely a court transcript or a motion filed in a criminal case. The text is written in a formal, legal style, and the formatting suggests that it is part of a larger document. The image does not contain any handwritten notes or other non-textual elements.