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our 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 effect here. To the contrary, th
6 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 follow up on your Honor's question
es v. Zinger, No. 00 Cr. 773, 2000 WL 1134364, at •1 8 EFTA00093087 C6sesel.213-Thilg240401Mt Db~t9tad420Ei1O3 tth M10 (E.D.N.Y. Aug. 4, 2000) (Gleeson, J.) (rejecting defendant's application for bail in part because home detention with electronic monitoring "at best . . . limits a fleeing defendant
ific and credible evidence, how Ms. Maxwell could manage to flee under the proposed bail conditions. Speculation is not permitted. United States v. Bodmer, No. 03-cr-947(SAS), 2004 WL 169790 (S.D.N.Y. Jan. 28, 2004) (where government's argument that no conditions could assure defendant's future presen
our 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 effect here. To the contrary, th
6 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 follow up on your Honor's question
Entities connected to both Gleeson and Bodmer

Jeffrey Epstein
PERSON
United States
LOCATION
Michael Jackson
PERSONthe Southern District
LOCATION
Southern District of New York
ORGANIZATIONSecond Circuit
ORGANIZATION
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATION
Michael Cohen
PERSON
Prince Andrew
PERSONAnnabi
PERSONBoustani
PERSON
United Kingdom
LOCATIONPretrial Services
ORGANIZATION
Bernie Madoff
PERSONMarc Dreier
PERSONKarni
PERSON
Geoffrey S. Berman
PERSONStroh
PERSONMoscaritolo
PERSON