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be N Ww ws Oo OY ~] oO Ke) Ww a OY 20 21 22 23 24 25 Case 21-770, Document 20-2, 04/01/2021, 3068530, Page114 of 200 51 k7e2MaxC kjc arrest. That defendant was released on bail conditions, strict bail conditions. And I mention Esposito, which is the 2019 case from Judge Marrero, that is a case in which the allegation was that the defendant was a senior ranking member of organized crime and had access to financial means as well. which I'm sure the court But all of those cases, as well is familiar, l as Madoff and Dreier, with involved allegations of defendants with hundreds o those cases, the courts held strict conditions. And by the way, cases, the defendants appeared appearances and appeared £ millions of Judge, for court. There are also cases pornography or sex crime for trial. allegations, coming from the Eastern District case in the Northern Dis trict of fF dollars, in all of that bail should be set subject to in all of those They all made from the context involving such as the Deutsch case several years ago, the Conway Calit understanding those ar that release could be awarded on condi the allegations, You even had one recently in Fornia. Again, the decision was made tions. the Second Circuit that I'm sure everyone is familiar with United States v. Mattis, different setting, because that was a dangerousness case and the government is not proceeding on dangerousness grounds, but threw a Molotov cocktail into a police car; that is the case where the allegation is that two attorneys challenge to bail SOUTHERN D STRICT R G! ‘PORT ERS, (212) 805-0300 P a Gs DOJ-OGR-00001055