DOJ-OGR-00001053.pdf

--- Page 1 --- **Document Header:** * **Case Number:** 21-770 * **Document Number:** 20-2 * **Date:** 04/01/2021 * **Page Number:** 112 of 200 **Page Content:** * **Text:** + that are relevant to that, which I was going to get to, your Honor, are Khashoggi, U.S. v. Khashoggi, U.S. v. Bodmer, U.S. + v. Hanson, and Sabhnani itself, all of which involve defendants with substantial connections. + And I might follow up on your Honor's question, when you take off the spin and you take off the media -- and I'm going to get to it in a moment, because your Honor is going to allow me to respond -- here is their case: Defendant is a citizen of more than one country, England and France, not exactly exotic places. The defendant has three passports. The defendant has traveled internationally in the past, not in the past year. There is no refutation from the government on that, and they have been all over her travel records. The defendant has resided here in the past year. She has traveled internationally and, according to the government, she has financial means. I will get to that in a moment, Judge. But let's assume for the purposes of this discussion that she has financial means and not the lies that the government laid out. What do those cases teach? They teach that that is something the court can and should address in the bail conditions. They teach that they may require stricter bail conditions. They don't teach that that means there should be no bail at all. In Sabhnani, a Second Circuit case, the allegation was that the defendants have held two individuals in slavery for five years, and they had many more international ties or international **Footer:** * **Southern District Reporters, P.C.** * **Phone Number:** (212) 805-0300 * **Document ID:** DOJ-OGR-00001053