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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
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
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
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
United States v. DiGiacomo, 746 F. Supp. 1176 (D. Mass. 1990) 14 United States v Dominguez, 783 F.2d 702 (7th Cir. 1986) 10 United States v Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009) 21 United States y English, 629 F.3d 311 (2d Cir. 2011) 10, 11 ii EFTA00018517 --- PAGE BREAK --- Cas
Page: EFTA00018517 →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 →n granted release subject to conditions), aff'd, 749 F. App'x 20 (2d Cir. 2018); United States v. Dreier, 596 F. Supp. 2d 831, 832 (S.D.N.Y. 2009) (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. S
Page: EFTA00018539 →Entities connected to both Sabhnani and Marc Dreier

Jeffrey Epstein
PERSONSecond Circuit
ORGANIZATION
United States
LOCATION
Bernie Madoff
PERSONBoustani
PERSON
Ghislaine Maxwell
PERSONKarni
PERSONthe Southern District
LOCATION
Mattis
PERSON
United Kingdom
LOCATION
Michael Cohen
PERSONPretrial Services
ORGANIZATION
Conway
PERSON
Hanson
PERSONBodmer
PERSONJeffrey Pagliuca
PERSONKhashoggi
PERSON
Stephen Hawking
PERSON
Department of Justice
ORGANIZATIONMorrison
PERSON