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ry of the defendant. The government said -- THE COURT: Mr. Cohen, just before you move to that, the three cases that you cited -- Esposito, Dreier, Madoff - factually did any of those cases involve defendants with substantial international and foreign connections? MR. COHEN: No, I don't believe they
ars to have been based on the resources available to defendant, not foreign connections or experience and a record of hiding from being found. In Madoff, the defendant had already been released on a bail package agreed to by the parties for a considerable period of time before the government sought
s hiding and we have evidence, your Honor, that the defendant was making plans to leave the country. That is the situation, frankly, in the U.S. v. Zarger case, the case by Judge Gleeson in 2000, that the government cites in its brief, but of course doesn't discuss the facts. There is nothing to that
ry of the defendant. The government said -- THE COURT: Mr. Cohen, just before you move to that, the three cases that you cited -- Esposito, Dreier, Madoff - factually did any of those cases involve defendants with substantial international and foreign connections? MR. COHEN: No, I don't believe they
ars to have been based on the resources available to defendant, not foreign connections or experience and a record of hiding from being found. In Madoff, the defendant had already been released on a bail package agreed to by the parties for a considerable period of time before the government sought
s hiding and we have evidence, your Honor, that the defendant was making plans to leave the country. That is the situation, frankly, in the U.S. v. Zarger case, the case by Judge Gleeson in 2000, that the government cites in its brief, but of course doesn't discuss the facts. There is nothing to that
The Court is unpersuaded. 13 EFTA00013319 --- PAGE BREAK --- United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009), and United States v. Madoff 586 F. Supp. 2d 240 (S.D.N.Y. 2009)). The Court's concerns regarding the absence of any dependents, significant family ties, or employment in the
Page: EFTA00013320 →observed, "home detention with electronic monitoring does not prevent flight; at best, it limits a fleeing defendant's head start." United States v. Zarger, No. 00- CR-773-S-1 (JG), 2000 WL 1134364, at *I (E.D.N.Y. Aug. 4, 2000). Furthermore, while the Defendant now represents that she would be released
Page: EFTA00013325 →Entities connected to both Bernie Madoff and Zarger

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Michael Cohen
PERSONMartin Weinberg
PERSON
Julie K. Brown
PERSON
Alexander Acosta
PERSONFrisco
LOCATIONRubin
PERSON
Audrey Strauss
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONSecond Circuit
ORGANIZATIONthe Southern District
LOCATION
Department of Justice
ORGANIZATIONJane Doe
PERSONMarc Dreier
PERSON
United Kingdom
LOCATIONBoustani
PERSONKarni
PERSON
Michael Jackson
PERSON