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be N Ww ws Oo OY ~] oO Ke) a oO = be N Ww fe ws Oo _ OY a ~] a oO a Ke) 20 21 22 28 24 25 Case 1:19-cr-00490-RMB Document 36 include a list of It does not include a list of financial institutions. what types of to identify identify high-value property such as diamonds or art, the currencies th location of defendant holds his holdings. which wer search of his The other the defendant' Manhattan man thing, y s word for al sion. our Honor, this. Ll of not under penalty of perjur There are no bank records. That! this would somehow rise it's notable with respec also with respect to how the Court evaluates the def assets that we are relying on him. The defendant's financial disclosure the Court, your Honor, not give it comfort that conditions that would keep the defendant from prevent him With respect to the proposed package, the defendant proposes the Court accept his Manhattan mansion as security for a bond. Now, the government has already designated that property for seizure making it worthless to the defendant. He from being a da Ss not to say Vy. There is nothing to validate this. that if Filed 07/24/19 accounts. Page 15 of 74 . It does nothing It It does not identify It does nothing to observed in abundance in just the government's is we're just relying on This is not sworn. 15 does not both of It's CO the level of t to the presumption in part There are no account statements. this were validated, that being granted bail, but icular and form should alarm there are Fleeing and nger. proposes cosigners who couldn't possibly sec ndant's SOUTHERN DIS TR CT REPORT (21 ERS, 2) 805-0300 P.C. ure a package DOJ-OGR-00000525