court filing: 1:17-cr-00330-AJN

The document is a court filing submitted by the Acting United States Attorney, Audrey Strauss, and Assistant United States Attorneys, arguing that the defendant's renewed bail motion should be denied due to the risk of flight. The court had previously found that the defendant poses a substantial actual risk of flight, and the government asserts that no conditions of bail can mitigate this risk. The motion is dated December 16, 2020.