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Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 48 of 91 48 k7e2MaxC kjc 1 conditions. So what we did is we went through all the high 2 profile cases in this courthouse in the past several years and 5 other cases, cases like Madoff, cases like Dreier, cases like 4 Esposito, where Judge Marrero ruled in 2018 relating to an 5 alleged member of organized crime, and we went through those 6 cases to find the conditions that were listed under 3142(c), 7 and in those cases that would we believe be relevant and 8 applicable here, and we believe we have listed them all. We 9 understand that of course they would be subject to 10 verification; and as we noted in our papers and I noted today, 1] if we could have a guarantee of safety, if we could have a 12 guarantee of privacy and confidentiality, and if the court 13 required it, we believe there are other suretors who we could 14 provide and perhaps other amounts of property as well. That is 15 an issue. It is a real issue in this case. It is something 16 the government is just avoiding, but it is real. 17 So let me talk now, your Honor, if I might, about the 18 3142(g) (3) factors, which are the factors relating to the 19 history of the defendant. 20 The government said —- 21 THE COURT: Mr. Cohen, just before you move to that, 22 the thr cases that you cited -- Esposito, Dreier, Madoff —- 23 factually did any of those cases involve defendants with 24 substantial international and foreign connections? 25 MR. COHEN: No, I don't believe they did. The cases SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00001925