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be N Ww ws Oo OY ~] oO Ke) a fan) = be N Ww = Hs Oo a OY a ~] a oO a Ke) 20 21 22 23 24 25 Case 21-58, Document 39-2, 04/01/2021, 3068530, Page116 of 200 k7e2MaxC kjc seeking millions of dollars Something She has also, froma as we mentioned, 53 fund that's being set up. for the court to consider. remained in the United States, even though she has known of the investigation. How could she not? It's been unbelievably public for the past year. And we have been in regular contact with her -- with the government. Your Honor asked that question, very careful question from the court, and we got a shimmy from the government in respons We have been in contact with them, conservatively -- as we checked last night, because we thought you might ask -- conservatively eight to ten times in the past year, all for the same purpose, to urge them not to bring this case, which shouldn't have been brought. The notion the government, that experienced counsel, Haddon Morgan is also experienced, would surrender and counsel at is in regular contact with their client, and they turn around and deny that to the court and deny surrender would and could have and should have been here is, we submit, another that voluntary possible fac For the court to consider. tor So let me turn to the reply brief. THE COURT: to make sure defense counsel indicated I understand Sorry. ie may, Mr. Cohen, just want that last point. Are you saying that to the government that, should there be an voluntary surrender? indictment returned, yo u were seeking CO arrange a Is that the contention? SOUTHERN D STRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00019975