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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, Page136 of 200 73 k7e2MaxC kjc the court, significantly And while we recognize that it appears that the defendant's extensive resources may be in complicated banking records, at a basic leve 1, the defense argument is that she the cannot remember o of dollars she has. Tha concern. A bail hearing, top of her head just how many millions t should cause the court serious your Honor, is not an opportunity for reveal in formation until the court the defendant to slowly deems it sufficient. That is not sufficient process here. That is not appropriate. This in formation is coming out in dribs and drabs, and defendant should not be in a position to slowly but surely concede, as th government reveals, that she has been less than candid with the court about her finances. There are serious concer ns here. With respect to the notion that the defendant could just surrender her passp orts, there are of course no limitations this court could set on a foreign government issuing travel documents were to enter into that to defendant or accepting her if she COUNLLY » And finally, your Honor, with respect to the case law that defense has cited, they ignore the obvious comparator case, which is Judge Berman's decision regarding Jeffrey dangerousness grounds. Epstein, who was arrested both on risk of flight grounds and on And as Judge Berman detailed, the SOUTHERN D STRICT R EPORTERS, P.C. (212) 805-0300 DOJ-OGR-00001077