DOJ-OGR-00000572.pdf

--- Page 1 --- **Document Image Extraction** **Case Number and Status** Case 1:19-cr-00490-RMB **Document Details** Document 36 Filed 07/24/19 Page 62 of 74 **Text Content** 1. in touch with the defense about. But there is a proven, existing example for how that works and how that works well. 2. What the defendant is asking for here is for special treatment to build his own jail, to have his own private jail that he gets to stay in away from everybody else who is in jail and have him be limited in his own gilded cage surrounded by people with guns, surrounded by trustees with cameras on all sides of his house. A person who needs those conditions should be detained. 3. Second, the issue of whether the case was brought to us, whether this was funneled to the Southern District of New York from anywhere else, your Honor, it was not. It was not brought to us by anyone else. 4. We opened the case. We investigated the case. By "we," I mean the FBI, CBP, the NYPD, and of course the U.S. Attorney's Office. We opened the case. We investigated the case. And I can tell you that not one of the prosecutors sitting at this table has spoken with anyone at the Southern District of Florida. 5. The issue of the Department of Justice appeal by the defendant is a distraction from the bail determination, your Honor. The chain of events that defense counsel describes makes clear that the Department of Justice did not have a role in negotiating the NPA. It didn't have any role in confirming if other. **Table** | **Row** | **Column** | | --- | --- | | 1 | in touch with the defense about. But there is a proven, existing example for how that works and how that works well. | | 2 | What the defendant is asking for here is for special treatment to build his own jail, to have his own private jail that he gets to stay in away from everybody else who is in jail and have him be limited in his own gilded cage surrounded by people with guns, surrounded by trustees with cameras on all sides of his house. A person who needs those conditions should be detained. | | 3 | Second, the issue of whether the case was brought to us, whether this was funneled to the Southern District of New York from anywhere else, your Honor, it was not. It was not brought to us by anyone else. | | 4 | We opened the case. We investigated the case. By "we," I mean the FBI, CBP, the NYPD, and of course the U.S. Attorney's Office. We opened the case. We investigated the case. And I can tell you that not one of the prosecutors sitting at this table has spoken with anyone at the Southern District of Florida. | | 5 | The issue of the Department of Justice appeal by the defendant is a distraction from the bail determination, your Honor. The chain of events that defense counsel describes makes clear that the Department of Justice did not have a role in negotiating the NPA. It didn't have any role in confirming if other. | **Footer** SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 **Page Number** Page 62 of 74 **Case Number and Status** Case 1:19-cr-00490-RMB **Document Details** Document 36 Filed 07/24/19 Page 62 of 74 **Text Content** 1. in touch with the defense about. But there is a proven, existing example for how that works and how that works well. 2. What the defendant is asking for here is for special treatment to build his own jail, to have his own private jail that he gets to stay in away from everybody else who is in jail and have him be limited in his own gilded cage surrounded by people with guns, surrounded by trustees with cameras on all sides of his house. A person who needs those conditions should be detained. 3. Second, the issue of whether the case was brought to us, whether this was funneled to the Southern District of New York from anywhere else, your Honor, it was not. It was not brought to us by anyone else. 4. We opened the case. We investigated the case. By "we," I mean the FBI, CBP, the NYPD, and of course the U.S. Attorney's Office. We opened the case. We investigated the case. And I can tell you that not one of the prosecutors sitting at this table has spoken with anyone at the Southern District of Florida. 5. The issue of the Department of Justice appeal by the defendant is a distraction from the bail determination, your Honor. The chain of events that defense counsel describes makes clear that the Department of Justice did not have a role in negotiating the NPA. It didn't have any role in confirming if other. **Table** | **Row** | **Column** | | --- | --- | | 1 | in touch with the defense about. But there is a proven, existing example for how that works and how that works well. | | 2 | What the defendant is asking for here is for special treatment to build his own jail, to have his own private jail that he gets to stay in away from everybody else who is in jail and have him be limited in his own gilded cage surrounded by people with guns, surrounded by trustees with cameras on all sides of his house. A person who needs those conditions should be detained. | | 3 | Second, the issue of whether the case was brought to us, whether this was funneled to the Southern District of New York from anywhere else, your Honor, it was not. It was not brought to us by anyone else. | | 4 | We opened the case. We investigated the case. By "we," I mean the FBI, CBP, the NYPD, and of course the U.S. Attorney's Office. We opened the case. We investigated the case. And I can tell you that not one of the prosecutors sitting at this table has spoken with anyone at the Southern District of Florida. | | 5 | The issue of the Department of Justice appeal by the defendant is a distraction from the bail determination, your Honor. The chain of events that defense counsel describes makes clear that the Department of Justice did not have a role in negotiating the NPA. It didn't have any role in confirming if other. | **Footer** SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 **Page Number** Page 62 of 74 **Case Number and Status** Case 1:19-cr-00490-RMB **Document Details** Document 36 Filed 07/24/19 Page 62 of 74 **Text Content** 1. in touch with the defense about. But there is a proven, existing example for how that works and how that works well. 2. What the defendant is asking for here is for special treatment to build his own jail, to have his own private jail that he gets to stay in away from everybody else who is in jail and have him be limited in his own gilded cage surrounded by people with guns, surrounded by trustees with cameras on all sides of his house. A person who needs those conditions should be detained. 3. Second, the issue of whether the case was brought to us, whether this was funneled to the Southern District of New York from anywhere else, your Honor, it was not. It was not brought to us by anyone else. 4. We opened the case. We investigated the case. By "we," I mean the FBI, CBP, the NYPD, and of course the U.S. Attorney's Office. We opened the case. We investigated the case. And I can tell you that not one of the prosecutors sitting at this table has spoken with anyone at the Southern District of Florida. 5. The issue of the Department of Justice appeal by the defendant is a distraction from the bail determination, your Honor. The chain of events that defense counsel describes makes clear that the Department of Justice did not have a role in negotiating the NPA. It didn't have any role in confirming if other. **Table** | **Row** | **Column** | | --- | --- | | 1 | in touch with the defense about. But there is a proven, existing example for how that works and how that works well. | | 2 | What the defendant is asking for here is for special treatment to build his own jail, to have his own private jail that he gets to stay in away from everybody else who is in jail and have him be limited in his own gilded cage surrounded by people with guns, surrounded by trustees with cameras on all sides of his house. A person who needs those conditions should be detained. | | 3 | Second, the issue of whether the case was brought to us, whether this was funneled to the Southern District of New York from anywhere else, your Honor, it was not. It was not brought to us by anyone else. | | 4 | We opened the case. We investigated the case. By "we," I mean the FBI, CBP, the NYPD, and of course the U.S. Attorney's Office. We opened the case. We investigated the case. And I can tell you that not one of the prosecutors sitting at this table has spoken with anyone at the Southern District of Florida. | | 5 | The issue of the Department of Justice appeal by the defendant is a distraction from the bail determination, your Honor. The chain of events that defense counsel describes makes clear that the Department of Justice did not have a role in negotiating the NPA. It didn't have any role in confirming if other. | **Footer** SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 **Page Number** Page 62 of 74 **Case Number and Status** Case 1:19-cr-00490-RMB **Document Details** Document 36 Filed 07/24/19 Page 62 of 74 **Text Content** 1. in touch with the defense about. But there is a proven, existing example for how that works and how that works well. 2. What the defendant is asking for here is for special treatment to build his own jail, to have his own private jail that he gets to stay in away from everybody else who is in jail and have him be limited in his own gilded cage surrounded by people with guns, surrounded by trustees with cameras on all sides of his house. A person who needs those conditions should be detained. 3. Second, the issue of whether the case was brought to us, whether this was funneled to the Southern District of New York from anywhere else, your Honor, it was not. It was not brought to us by anyone else. 4. We opened the case. We investigated the case. By "we," I mean the FBI, CBP, the NYPD, and of course the U.S. Attorney's Office. We opened the case. We investigated the case. And I can tell you that not one of the prosecutors sitting at this table has spoken with anyone at the Southern District of Florida. 5. The issue of the Department of Justice appeal by the defendant is a distraction from the bail determination, your Honor. The chain of events that defense counsel describes makes clear that the Department of Justice did not have a role in negotiating the NPA. It didn't have any role in confirming if other. **Table** | **Row** | **Column** | | --- | --- | | 1 | in touch with the defense about. But there is a proven, existing example for how that works and how that works well. | | 2 | What the defendant is asking for here is for special treatment to build his own jail, to have his own private jail that he gets to stay in away from everybody else who is in jail and have him be limited in his own gilded cage surrounded by people with guns, surrounded by trustees with cameras on all sides of his house. A person who needs those conditions should be detained. | | 3 | Second, the issue of whether the case was brought to us, whether this was funneled to the Southern District of New York from anywhere else, your Honor, it was not. It was not brought to us by anyone else. | | 4 | We opened the case. We investigated the case. By "we," I mean the FBI, CBP, the NYPD, and of course the U.S. Attorney's Office. We opened the case. We investigated the case. And I can tell you that not one of the prosecutors sitting at this table has spoken with anyone at the Southern District of Florida. | | 5 | The issue of the Department of Justice appeal by the defendant is a distraction from the bail determination, your Honor. The chain of events that defense counsel describes makes clear that the Department of Justice did not have a role in negotiating the NPA. It didn't have any role in confirming if other. | **Footer** SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 **Page Number** Page 62 of 74 **Case Number and Status** Case 1:19-cr-00490-RMB **Document Details** Document 36 Filed 07/24/19 Page 62 of 74 **Text Content** 1. in touch with the defense about. But there is a proven, existing example for how that works and how that works well. 2. What the defendant is asking for here is for special treatment to build his own jail, to have his own private jail that he gets to stay in away from everybody else who is in jail and have him be limited in his own gilded cage surrounded by people with guns, surrounded by trustees with cameras on all sides of his house. A person who needs those conditions should be detained. 3. Second, the issue of whether the case was brought to us, whether this was funneled to the Southern District of New York from anywhere else, your Honor, it was not. It was not brought to us by anyone else. 4. We opened the case. We investigated the case. By "we," I mean the FBI, CBP, the NYPD, and of course the U.S. Attorney's Office. We opened the case. We investigated the case. And I can tell you that not one of the prosecutors sitting at this table has spoken with anyone at the Southern District of Florida. 5. The issue of the Department of Justice appeal by the defendant is a distraction from the bail determination, your Honor. The chain of events that defense counsel describes makes clear that the Department of Justice did not have a role in negotiating the NPA. It didn't have any role in confirming if other. **Table** | **Row** | **Column** | | --- | --- | | 1 | in touch with the defense about. But there is a proven, existing example for how that works and how that works well. | | 2 | What the defendant is asking for here is for special treatment to build his own jail, to have his own private jail that he gets to stay in away from everybody else who is in jail and have him be limited in his own gilded cage surrounded by people with guns, surrounded by trustees with cameras on all sides of his house. A person who needs those conditions should be detained. | | 3 | Second, the issue of whether the case was brought to us, whether this was funneled to the Southern District of New York from anywhere else, your Honor, it was not. It was not brought to us by anyone else. | | 4 | We opened the case. We investigated the case. By "we," I mean the FBI, CBP, the NYPD, and of course the U.S. Attorney's Office. We opened the case. We investigated the case. And I can tell you that not one of the prosecutors sitting at this table has spoken with anyone at the Southern District of Florida. | | 5 | The issue of the Department of Justice appeal by the defendant is a distraction from the bail determination, your Honor. The chain of events that defense counsel describes makes clear that the Department of Justice did not have a role in negotiating the NPA. It didn't have any role in confirming if other. | **Footer** SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 **Page Number** Page 62 of 74 **Case Number and Status** Case 1:19-cr-00490-RMB **Document Details** Document 36 Filed 07/24/19 Page 62 of 74 **Text Content** 1. in touch with the defense about. But there is a proven, existing example for how that works and how that works well. 2. What the defendant is asking for here is for special treatment to build his own jail, to have his own private jail that he gets to stay in away from everybody else who is in jail and have him be limited in his own gilded cage surrounded by people with guns, surrounded by trustees with cameras on all sides of his house. A person who needs those conditions should be detained. 3. Second, the issue of whether the case was brought to us, whether this was funneled to the Southern District of New York from anywhere else, your Honor, it was not. It was not brought to us by anyone else. 4. We opened the case. We investigated the case. By "we," I mean the FBI, CBP, the NYPD, and of course the U.S. Attorney's Office. We opened the case. We investigated the case. And I can tell you that not one of the prosecutors sitting at this table has spoken with anyone at the Southern District of Florida. 5. The issue of the Department of Justice appeal by the defendant is a distraction from the bail determination, your Honor. The chain of events that defense counsel describes makes clear that the Department of Justice did not have a role in negotiating the NPA. It didn't have any role in confirming if other. **Table** | **Row** | **Column** | | --- | --- | | 1 | in touch with the defense about. But there is a proven, existing example for how that works and how that works well. | | 2 | What the defendant is asking for here is for special treatment to build his own jail, to have his own private jail that he gets to stay in away from everybody else who is in jail and have him be limited in his own gilded cage surrounded by people with guns, surrounded by trustees with cameras on all sides of his house. A person who needs those conditions should be detained. | | 3 | Second, the issue of whether the case was brought to us, whether this was funneled to the Southern District of New York from anywhere else, your Honor, it was not. It was not brought to us by anyone else. | | 4 | We opened the case. We investigated the case. By "we," I mean the FBI, CBP, the NYPD, and of course the U.S. Attorney's Office. We opened the case. We investigated the case. And I can tell you that not one of the prosecutors sitting at this table has spoken with anyone at the Southern District of Florida. | | 5 | The issue of the Department of Justice appeal by the defendant is a distraction from the bail determination, your Honor. The chain of events that defense counsel describes makes clear that the Department of Justice did not have a role in negotiating the N