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be N Ww ws Oo OY ~] oO Ke) Ww a OY 20 21 22 23 24 25 Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 49 of 91 k7e2MaxC kijc that are relevant to that, Honor, are Khashoggi, v. Hanson, and Sabhnani with substantial connections. And I might you take of going to get allow me to respond -- here is citizen of exactly exotic places. The de internat defendant has traveled the spin and you take o to it in a moment, more than one country, tional their case: England fendant has ly in past year. There is no refuta tion and they have been all over her travel records. and France, three passports. 49 which I was going to get to, your U.S. v. Khashoggi, U.S. v. Bodmer, U.S. itself, all of which involve defendants follow up on your Honor's question, when F£ the media -- and I'm because your Honor is going to Defendant is a not The the past, From the government on that, has resided her internationally and, financial means. let's assume What do those cases teach? the court teach in the past year. for the purposes of financial means and not the lies They can and should address according to the government, I will get to that in a moment, don't teach that that means there shoul that they may require stricter bail She has traveled in the bail conditions. conditions. , the allegation was Sabhnani, a Second Circuit cas defendants have held two individuals in sl The defendant Judge. not in the she has But this discussion that she has that the government laid out. teach that that is something They They ld be no bail at all. In that the avery for five years, and they had many more international ties or international SOUTHERN DISTRIC T REPORTERS, (212) 805-0300 DOJ-OGR-00001926