DOJ-OGR-00019973.pdf

Case 21-58, Document 39-2, 04/01/2021, 3068530, Page114 of 200 1 arrest. That defendant was released on bail conditions, strict bail conditions. 2 3 And I mention Esposito, which is the 2019 case from 4 Judge Marrero, that is a case in which the allegation was that 5 the defendant was a senior ranking member of organized crime 6 and had access to financial means as well. 7 8 But all of those cases, as well as Madoff and Dreier, 9 which I'm sure the court is familiar, with involved allegations 10 of defendants with hundreds of millions of dollars, in all of 11 those cases, the courts held that bail should be set subject to 12 strict conditions. And by the way, Judge, in all of those 13 cases, the defendants appeared for court. They all made 14 appearances and appeared for trial. 15 16 There are also cases from the context involving 17 pornography or sex crime allegations, such as the Deutsch case 18 coming from the Eastern District several years ago, the Conway 19 case in the Northern District of California. Again, 20 understanding those are the allegations, the decision was made 21 that release could be awarded on conditions. 22 23 You even had one recently in the Second Circuit that 24 I'm sure everyone is familiar with United States v. Mattis, 25 different setting, because that was a dangerousness case and 26 the government is not proceeding on dangerousness grounds, but 27 that is the case where the allegation is that two attorneys 28 threw a Molotov cocktail into a police car; challenge to bail SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00019973