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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, Page122 of 200 k7e2MaxC kjc 59 mentioned in its presentation, both in its papers and today, that relates to 3142(g) (3), which is the defendant's financial Situation. Again, when you look at the case law, which is not addressed by the government at all, this is a person who has passports that can be surrendered, who has travel that can be restricted, who has citizenship that the courts have taking account of, and does have financial means. Does she have th assume for purposes of financial means that the government says she has? We doubt it. But does she have hundreds of millions of dollars like those in the Madoff and Dreier case? No. But it doesn't matter. Even if the court were to today's proceeding that she has the means that the government claims she does, it does not affect the analysis. That is addressed if the court to be addressed in conditions, to be requires it, through verifications and further proceedings bef Fore the court. And let me just address some of the allegations made in the government's brief about her financial situation. The government goes out and arrests our client even though she would have voluntarily surrendered, arrests her the day before a federal holiday, so she spends extra time in the New Hampshire prison before being transported here, and then says, how come you don t have a full account of your financial condition? How come, when Pretrial Services asked about it, SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00019981