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Case 1:19-cr-00830-AT Document14 Filed 12/16/19 Page8of12 8 JBIJKNOEN 1 that that one condition be withheld and with all the other 2 conditions being fine. 3 THE COURT: Just so I understand your argument, you 4 would like your client to retain her personal-use firearm 5 because she otherwise has the right to do so? She doesn't need 6 it for any particular reason? 7 MR. FOY: Well, I suppose a person who has a firearm 8 may feel that they need it for their self-protection. Now, I'm 9 not suggesting that there's been some specific threat or 10 anything, other than the world is crazy, but if she hasn't done 11 anything improper with regards to that important right, it 12 shouldn't be sacrificed now, at an arraignment, as a condition 13 of her release, when she has fully cooperated with everything 14 up until this point. We've been in communication with the 15 government since August 14th, and communicated about her 16 international travel since this investigation began. All we've 17 done is comply and put the government on notice as to her 18 whereabouts and what's going on. We've been completely 19 cooperative in that respect. 20 But when you talk about removing someone's personal 21 firearm, that they legally possess in their hom she doesn't 22 have a license to carry it anywhere, just in her home - unless 23 there is a reason connected to the case, to the crime, that 24 suggests that it could be in fact a danger to a third party or 25 someon lse, then, in that case, I would understand, but not SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00021966