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be NO Ww ws Oo OY ~] oO Ke} a oO he be No (ee) = Hs Oo _ 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 60 of 91 60 k7e2MaxC kjc you can't, off the top of your head, condition to them? You must be absurd. explain your financial lying. That assertion is We have been working since our client was detained, with our client, trying to acce best we could, a financial pict ss family members to put, as ure befor extent it is relevant to this application the court to the and only this application. This bail proceeding should not turn into some mini investigation of our clien has had ten years to investigat t's finances. The government e my client. Let me address some of the specit Fic allegations in the government's brief. They point to a sale of property in 2016. According to the government, the property was sold for $15 million. There is no secret about that. Those records are out there. The government claims our client cleared $14 million from that in 2016 and apparently has it all today, which would probably make it the first New York real estate transaction to that effect. There has been liabilities. expenses. Our client has been through ex litigation all over this country denying in Khashoggi, far lower than that There has been tensive, substantial these claims. We think the number is far less than what the government asserts. But even taking that number, it's a number far lower than that in Dreier, far lower than in many cases, and the impact of t hat, in the court's discretion, should be addressed by bail conditions. SOUTHERN DISTRICT (212) 805-0300 REPORTERS, P.C. DOJ-OGR-00001937