DOJ-OGR-00001066.jpg

be N Ww ws Oo OY ~] oO Ke) a fan) = be N Ww = Hs Oo a OY a ~] a oO a Ke) 20 21 22 23 24 25 Case 21-770, Document 20-2, 04/01/2021, 3068530, Page125 of 200 62 k7e2MaxC kjc her. funds Well, when the bank drops you, you have to transfer your out. That's true. That's what happened. So there is nothing in there that's sinister, there is nothing in there SDAR, I might. One last point on the financial stuff, your Honor, if that shows an intent to evade, an intent to evade, and nothing there that we think warrants detention. a foreign fil In the reply brief, we get a new allegation that an ing was made in 2018 and 2019, disclosing that our client had a foreign bank account. Let's stop there. Our client makes a legally required filing with the Treasury account, and the government is claiming that's evidence of is al Department, obeys the law, and discloses a foreign bank hiding. This 3142. l upside-down, your Honor. These are not factors to be considered in exercising your discretion under Let me turn very quickly to the other two factors that are relevant for today's purposes because, as your Honor has pointed out, the government is not proceeding on a dangerousness claim. That is the (g)(1) and (g) (2) factors, the nature and circumstances of the case, and the weight of the evidence. Honor, said, Here, here, one Judge Raggi made in [ think we -- if you bear with me a moment, your thing to keep in mind is an observation the Sabhnani case, at page 77, where she "The mor Fectively a court can physically restrain the SOUTH BERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00001066