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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
at we did is we went through all the high profile cases in this courthouse in the past several years and other cases, cases like Medoff, cases like Dreier, cases like Esposito, where Judge Marrero ruled in 2018 relating to an alleged member of organized crime, and we went through those cases to find
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
at we did is we went through all the high profile cases in this courthouse in the past several years and other cases, cases like Medoff, cases like Dreier, cases like Esposito, where Judge Marrero ruled in 2018 relating to an alleged member of organized crime, and we went through those cases to find
intending to resist any subsequent extradition that might result. 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
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 Zarger and Marc Dreier

Jeffrey Epstein
PERSONSecond Circuit
ORGANIZATION
United States
LOCATION
Bernie Madoff
PERSONBoustani
PERSON
Ghislaine Maxwell
PERSONKarni
PERSON
United Kingdom
LOCATIONthe Southern District
LOCATION
Mattis
PERSON
Michael Cohen
PERSONPretrial Services
ORGANIZATION
Michael Jackson
PERSON
Conway
PERSON
Hanson
PERSONMartir
PERSONBodmer
PERSONKhashoggi
PERSONMorrison
PERSONStroh
PERSON