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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
se, to be addressed in the conditions. Doesn't mean the government has carried its burden of showing there is no combination of conditions. In the Khashoggi case, written by Judge Keenan in 1989, this was a person of extraordinary wealth, way more than anything the government alleges that our client has
6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 that are relevant to that, which I was going to get to, your Honor, are Khashoggi, U.S. v. Khashoggi, U.S. v. Bodmer, U.S. v. Hanson, and Sabhnani itself, all of which involve defendants with substantial connections. And I might
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
se, to be addressed in the conditions. Doesn't mean the government has carried its burden of showing there is no combination of conditions. In the Khashoggi case, written by Judge Keenan in 1989, this was a person of extraordinary wealth, way more than anything the government alleges that our client has
6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 that are relevant to that, which I was going to get to, your Honor, are Khashoggi, U.S. v. Khashoggi, U.S. v. Bodmer, U.S. v. Hanson, and Sabhnani itself, all of which involve defendants with substantial connections. And I might
o appeal an extradition order has been recognized as an indication of the defendant's intent not to flee." Def. Mot. at 27 (citing United States v. Khashoggi, 717 F. Supp. 1048, 1052 (S.D.N.Y. 1989)). The Court places little weight on this argument. Under the Defendant's theory, a defendant could strategi
Page: EFTA00013319 →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 Zarger and Khashoggi

Jeffrey Epstein
PERSONSecond Circuit
ORGANIZATION
United States
LOCATION
Ghislaine Maxwell
PERSONBoustani
PERSON
Michael Cohen
PERSON
United Kingdom
LOCATION
New Hampshire
LOCATION
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
Contreras
PERSONPetrov
PERSONKarni
PERSONSalvagno
PERSONMorrison
PERSON
Prince Andrew
PERSONMarc Dreier
PERSON
Bernie Madoff
PERSON
Stephen Hawking
PERSONRaniere
PERSON