DOJ-OGR-00001950.jpg

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 73 of 91 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, Lop of fF her head just how many millions t should cause the court serious your Honor, is not an opportunity for information until the court the defendant to slowly reveal deems it sufficient. That is not sufficient process here. That is not appropriate. This information is coming out in dribs and drabs, and defendant should not be in a position to slowly but surely concede, as the government reveals, that she has been less than candid with the court about her finances. There are serious concerns here. With respect to the notion that the defendant could just surrender her passports, there are of course no limitations this court could set on a foreign government issuing travel documents to det were to enter into that fendant 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 STR CT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00001950