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ay Case 21-770, Document 20-2, 04/01/2021, 3068530, Page121 of 200 58 k7e2MaxC kjc regular contact with the government, N Ww ws Oo OY ~] oO Ke) a fan) a fe N Ww = Hs Oo a OY a ~] a oO a Ke) 20 21 22 23 24 25 in the United State to come on some iss learned this, your Honor. case for ten years, So let me government made arg 31(g) (3), the histo heard several times be warranted becaus S think that those kinds of ues, tomorrow and the next day, your Honor, turn umen ry a tha th That's the opposite of now to another F hiding. Facts, I'm sure, I'm sure we will hav okay? is removed in a property So we your Honor, if your Honor decides to keep the proceedings open and give us a chance all with the disclaimer, t about briefly, two nd characteristics o factor tha more f the det t there was a -—- tha your Honor, we submit analysis that the c First and presumed innocent; the perjury, if the court has been someone who denies guilt, in a deposition did you do that and says no, charges them with perjury. Ourt and, foremost, re is a perjury charge. this does not has to perform. secondly, that it's an indicted charge, weight the court would give a not indicted charge. who says the defendant the weight it should be given Let me turn to another they are stil is, of some more facts we just They have been investigating this t the factors under fendant. We t detention should Very quickly, t tip the balance in the 3142 course, the allegation and nature of they are innocent, the government through the indictment, is is asked That is not -- other than the fact 1 entitled to the That's all SOUTH BRN DISTRICT REPORTERS, (212) 805-0300 P a Gs factor that the government DOJ-OGR-00001062