DOJ-OGR-00019982.pdf

Case 21-58, Document 39-2, 04/01/2021, 3068530, Page123 of 200 60 you can't, off the top of your head, explain your financial condition to them? You must be lying. That assertion is absurd. We have been working since our client was detained, with our client, trying to access family members to put, as best we could, a financial picture before the court to the extent it is relevant to this application and only this application. This bail proceeding should not turn into some mini investigation of our client's finances. The government has had ten years to investigate my client. Let me address some of the specific allegations in the government's brief. They point to a sale of property in 2016. According to the government, the property was sold for $15 million. There is no secret about that. Those records are out there. The government claims our client cleared $14 million from that in 2016 and apparently has it all today, which would probably make it the first New York real estate transaction to that effect. There has been liabilities. There has been expenses. Our client has been through extensive, substantial litigation all over this country denying these claims. We think the number is far less than what the government asserts. But even taking that number, it's a number far lower than that in Khashoggi, far lower than that in Dreier, far lower than in many cases, and the impact of that, in the court's discretion, should be addressed by bail conditions. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00019982