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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, Page130 of 200 k7e2MaxC kjc originally without prejudice obviously for precisely the picture of but it sounded like you were that her current detention was in some way by design her financial I am not saying that, proceeding we are having, suggesting to prevent you from providing a full Situation. Is MR. COHEN: No, am not going that far. What a client who will voluntary surrender, country despite an investiga chooses to arrest her and de instances your access to the tion, and tain her, client. COVI D crisis and the other in Stephens and in Williams—Bethea, us to pull together this Financial in m saying is, that the implication you are making? your Honor. I when you have a who is staying in the the government instead that limits in the early It is complicated by the factors your Honor has pointed out done it as quickly as we could before notion that my client should have been able to answer o top of her head the questions from Pretrial and so it is very hard for formation, and we have the court. But the ff the Services about a real estate transaction, for sense. That's THE COURT: Okay. MR. COHEN: in the schedule w example, set today -—- thank you, approving that least until November to complete all electronic discovery. They have told | discovery, just doesn't make any the point we are making. One last point in that regard, your Honor, your Honor, for the government is saying that it needs at including us that there are two SOUTHERN D STR CT REPORTERS, P.C. (212) 805-0300 67 DOJ-OGR-00001071