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fe 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 Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 50 of 91 50 k7e2MaxC kjc travel than alleged as to our client, year, conditions. In Bodmer, certainly in the past and strict release was approved with strict bail which was before Judge Scheindlin in 2004, the position it proceedings in the United observed, well, citizen of So, too, here. the defendant was a Swiss citizen, and Switzerland had taken would not extradite its citizens for States. And Judge Scheindlin if that becomes the test for bail, then no Switzerland can ever get bail in the United States. If that's the test for France, then no French citizen, under the government's reasoning, could ever get bail in the United States. And in Bodmer it was even th cas allegation th that the defendant who was a fraud cas was a Swiss attorney had, opening up Swiss accounts overseas and of hiding. have said in conditions. In the LOSo, anything the government alleges that our client has, according to the government, a had not been in SOUTHERN D Even with all that, this courthouse, of showing there is no combination of this was a person of extraordinary wealth, the allegation was according to the government, been that that was some form the court said what many courts to be addressed in the Doesn't mean the government has carried its burden conditions. Khashoggi case, written by Judge Keenan in way more than he was, a Saudi citizen who fugitive, the United States for three years prior to his STRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00001927