DOJ-OGR-00019982.jpg

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 21-58, Document 39-2, 04/01/2021, 3068530, Page123 of 200 60 k7e2MaxC kjc you can't, off the top of your condition to them? You must be lying. absurd. head, explain your financial That assertion is We have been working since our client was detained, with our client, trying to access family members to put, as best we could, a financial picture 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 client's has had ten years to investiga te my client. finances. The government Let me address some o £ the specific allegations in the government's brief. They poin t 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 litigation all over this country denying in Khashoggi, far lower than that through ext 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 that, in the court's discretion, should be addressed by bail conditions. SOUTHERN DISTRIC IT REPORTERS (212) 805-0300 ¢ PaGas DOJ-OGR- 00019982