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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 1:19-cr-00830-AT Document 14 JBJKNOEN With regards to that your Honor not make ask record of any kind or any history of firearm was involved, the surrender of Filed 12/16/19 Page 7 of 12 7 Firearm, I'm asking that a requirement of her release. that because - in this nonviolent allegation, in which no with a history ot legally possesses and has a permit for still convicted She V6 __ | be able to possess her THE COURT: Is that a duty MR. FOY: Personal. fF having no criminal fF violence - she, who the firearm, should firearm because she's not a felon and someone who's not permitted to do so. firearm or personal use? So that's the only issue that that at this time, to sacrit has, and has complied wi that firearm, that she st that there could be an argument about safety of however, Fice that ri th everything t I have, because I think ght that she legally hat it means to have till be able to do so. could imagine others; her continuing to possess her past, surrendered. We participated in a pretrial firearm, would actually endanger anyone. there's nothing to really corroborate the fact that just like she has in the We voluntarily interview. There's just no reason for it, other than probably a policy that says that's what they would like to do. Now, it's a meaningful one, I'm not saying that it's a bad thing, but under the unique circumstances here, in this case, in the history and type of case that it is, I'm asking SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00021965