DOJ-OGR-00001067.jpg

fe NO 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 Case 21-770, Document 20-2, 04/01/2021, 3068530, Page126 of 200 63 k7e2MaxC kjc defendant, the less important it becomes to identify and restrain each and every asset over which defendants may xercise some control in order to mitigate risk of flight." So if the court -- and we have suggested them, but they may be modified by the court -- can put in place stringent bail conditions, hearing about her in detention. That Sabhnani. Judge, the offense and the weigh your Honor, this is the p is a bail hearing. It is legal questions that we don't need to have a side-long, month—-Long very quickly on the nature and circumstances of th t of lace not videnc my client's assets which is just designed to keep was an observation by Judge Raggi in we don't think, to litigate legal motions. we will be presenting to your Honor. the court This the place to litigate complex It's for Ficant w things that very soon on the motion schedule, and we thank agreeing to the schedule. But there are a f worth pointing out. We believe there are very signit that will affect whether this shape of this indictment and, given the government's representation that it is not planning to supersede, th affect the shape of ntir proceeds before the court is exactly what we submit exercising its discretion case, at trial, if there will is a trial. the court can consider, as to the weight of SOUTHERN D STRICT RE PORT ERS, (212) 805-0300 2) again, the L ale motions here indictment survives at all or the or any case at all that That in evidence. DOJ-OGR-00001067