DOJ-OGR-00000571.pdf

Case 1:19-cr-00490-RMB Document 36 Filed 07/24/19 Page 61 of 74 61 5:00. That's no problem. THE COURT: Fair enough. MR. ROSSMILLER: I can't say whether we will, but we'll certainly re-examine the record. THE COURT: So you'll look at the record, so to speak, and what we discussed here today and see where there could be some more strength in terms of evidence. MR. ROSSMILLER: Yes, your Honor. Just very briefly to respond, and I'll try to go sort of lightning round through some of these. Starting at the very beginning with this issue of being able to prepare a case having access to counsel, the idea that detention impairs the ability to prepare a defense -- this is certainly a challenging case. It's a significant case. This Court has significant experience with precisely that type of case with a detained defendant in Zarrab. In that case, I think the Court saw -- and the country and the world saw -- that it is eminently possible for a defendant to have excellent, excellent counsel and every opportunity to consult with that counsel while detained and while detained here. I'm not specifically familiar with the conditions of Mr. Zarrab's detention, but my general understanding is that there were concessions made with respect to his ability to review documents and have space. Those are certainly factors that we're willing to be SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00000571