DOJ-OGR-00019989.pdf

Case 21-58, Document 39-2, 04/01/2021, 3068530, Page130 of 200 67 originally without prejudice obviously for precisely the proceeding we are having, but it sounded like you were suggesting that her current detention was in some way by design to prevent you from providing a full picture of her financial situation. Is that the implication you are making? MR. COHEN: No, I am not saying that, your Honor. I am not going that far. What I am saying is, when you have a client who will voluntary surrender, who is staying in the country despite an investigation, and the government instead chooses to arrest her and detain her, that limits in the early instances your access to the client. It is complicated by the COVID crisis and the other factors your Honor has pointed out in Stephens and in Williams-Bethea, and so it is very hard for us to pull together this financial information, and we have done it as quickly as we could before the court. But the notion that my client should have been able to answer off the top of her head the questions from Pretrial Services about a real estate transaction, for example, just doesn't make any sense. That's the point we are making. THE COURT: Okay. MR. COHEN: One last point in that regard, your Honor, in the schedule we set today -- thank you, your Honor, for approving that -- the government is saying that it needs at least until November to complete all discovery, including electronic discovery. They have told us that there are two SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00019989