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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
n that never shifts, has not made a showing as required, that our client is a risk of flight. When you consider the risk, as Judge Raggi put it, in Sabhnani, the actual risk of flight, not fantasy and not speculation, when you consider that the only factors they really point to are ones that the cases
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
n that never shifts, has not made a showing as required, that our client is a risk of flight. When you consider the risk, as Judge Raggi put it, in Sabhnani, the actual risk of flight, not fantasy and not speculation, when you consider that the only factors they really point to are ones that the cases
WL 3536277 (2d Cir. June 30, 2020) 10 United States v. Moscaritolo, No. 10 Cr. 4 (JL), 2010 WL 309679 (D.N.H. Jan. 26, 2010) 18 United States v. Sabhnani, 493 F.3d 63 (2d Cir. 2007) 9, 10, 16, 18 United States v. Salerno, 481 U.S. 739 (1987) 9 United States v. Stephens, 15-CR-95 (AJN), 2020 WL 1
Page: EFTA00018518 →09) (Marc Dreier, accused of "colossal criminality" and alleged to be a "high flight risk," granted release subject to conditions); United States v. Madoff, 586 F. Supp. 2d 240, 243 (S.D.N.Y. 2009) (Bernie Madoff, charged with "largest Ponzi scheme ever and alleged to be a "serious risk of flight," gra
Page: EFTA00018540 →and alleged to be a "high flight risk," granted release subject to conditions); United States v. Madoff, 586 F. Supp. 2d 240, 243 (S.D.N.Y. 2009) (Bernie Madoff, charged with "largest Ponzi scheme ever and alleged to be a "serious risk of flight," granted release subject to conditions). not have Ms. Maxwell
Page: EFTA00018540 →Entities connected to both Bernie Madoff and Sabhnani

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Michael Cohen
PERSON
Julie K. Brown
PERSON
Denver
LOCATIONMartin Weinberg
PERSON
Alexander Acosta
PERSONRubin
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONthe Southern District
LOCATIONSecond Circuit
ORGANIZATION
Department of Justice
ORGANIZATIONJane Doe
PERSONMarc Dreier
PERSONBoustani
PERSON
United Kingdom
LOCATIONKarni
PERSON
Stephen Hawking
PERSON
Geoffrey S. Berman
PERSON