DOJ-OGR-00001069.jpg

ay Case 21-770, Document 20-2, 04/01/2021, 3068530, Page128 of 200 65 k7e2MaxC kjc litigation before your Honor about what is in the NPA, and the 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 government, we expect, is going to take the unlike '0O07 is covered and nothing else. We which we will lay out for your Honor. What decide we will reach back and indict '94 to position that disagree with that, do they do? They '97, totally where the conduct tactical, your Honor. So now we have a cas is 25 years old, no tapes, no video, none of the sort of things you would expect in that age of case, that we are going to have to defend, and we are going to defend. And I think it goes to the court's consideration of the weight in the context of the only application that's before your Honor, which is how to weigh the 3142 factors with the structure of F the statute, with the guidance of the Second Circuit and the Supreme Court, which is in favor of bail, in favor of bail on appropriate conditions. So we submit that the package we laid out for the court is sufficient that we are certainly willing if the court deems it necessary to leave the proceeding open and we think we could be back before the court within a week if that is what the court wants or there is more detail which has been hammered by the fact that our client has been, by design, by design, kept in custody. And let me just give your flavor. THI! GI could you repeat it, please. Honor a little COURT: Wait, Mr. Cohen. I missed that last point SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00001069