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be No Ww ws oO OY ~] oO Ke} ha oO he be N Ww = ws Oo a OY = ~] a oO a Ke) 20 21 22 23 24 25 Case 1:19-cr-00490-RMB Document36_ Filed 07/24/19 Page 51 of 74 ool. Whereas, in our bail submissions -- and they were admittedly rushed -—- we did what we could amongst defense counsel. We want the Court to know that whatever monetary conditions, Judge, you believe are necessary and appropriate to meet the imperatives of the Bail Reform Act, which is to reasonably assure his appearance. And I would go farther, to virtually guarantee his appearance, in combination with the home detention and monitoring and limitation of communications he would accept. He would sign any bond, and he would give your Honor and the United States District Court clerk whatever collateral the Court ordered. Likewise, were your Honor to consider monetary conditions, we would provide a more particularized list believing that monitoring his accounts and making sure that they didn't fall beneath the level of the personal recognizance bail would be appropriate. Again, I think to some extent, I'm backing into the answer to question three which is the sealing question and whether the financial information should be public. [ think if your Honor is to grant bail that includes the monetary conditions, then this becomes a judicial document that is at the heart of a bail release order, and the public is entitled to it. [ think if your Honor is to determine that release is SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00000561