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unding the practice, we respectfully propose it here as a fallback, asking the Court to revisit its propriety despite the reservations expressed in Zarrab. Those reservations, though admirably motivated and sincerely held, raise substantial equal protection concerns. They impair the statutory right to
of Denmark-from where defendant could not be extradited-charged with bulk cash smuggling and forfeiture, noting that the 9 This Court's opinion in Zarrab stands only for the proposition that wealthy defendants should not be provided an unfair advantage. It does not, of course, suggest that wealthy def
08), modification denied, 2008 WL 11339654 (E.D.N.Y. July 2, 2008). See United States v. Esposito, 749 F. App'x 20 (2d Cir. 2018); United States v. Sablznani, 493 F.3d 63 (2d Cir. 2007). 10 EFTA00058438 Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 11 of 16 Other than his 2008 guilty plea pre
ented to him did "not appear to contemplate 'release' so much as it describes a very expensive form of private jail or detention." United States v. Zarrab, 2016 WL 3681423, at *10 (S.D.N.Y. June 16, 2016). Courts have long been troubled by private jail proposals like the defendant's which, "at best 'e
Page: EFTA00015539 →rrectly notes, federal prisoners should be detained in facilities run by trained personnel from federal correctional facilities." Id. at 258 (citing Sablznani, 493 F.3d at 74 n.13 ("To the extent [armed private guards] implies an expectation that deadly force may need to be used to assure defendant['s] pr
Page: EFTA00015540 →ented to him did "not appear to contemplate 'release' so much as it describes a very expensive form of private jail or detention." United States v. Zarrab, 2016 WL 3681423, at *10 (S.D.N.Y. June 16, 2016). Courts have long been troubled by private jail proposals like the defendant's which, "at best 'e
Page: EFTA00028792 →rrectly notes, federal prisoners should be detained in facilities run by trained personnel from federal correctional facilities." Id. at 258 (citing Sablznani, 493 F.3d at 74 n.13 ("To the extent [armed private guards] implies an expectation that deadly force may need to be used to assure defendant['s] pr
Page: EFTA00028793 →Entities connected to both Zarrab and Sablznani

Jeffrey Epstein
PERSON
Reid Weingarten
PERSONMartin Weinberg
PERSON
Harry Reid
PERSON
Department of Justice
ORGANIZATION
Geoffrey S. Berman
PERSON
Alexander Acosta
PERSON
Richard M. Berman
PERSON
United States
LOCATIONPretrial Services
ORGANIZATIONBonestroo
PERSONFBI
ORGANIZATIONEmmy Taylor
PERSON
George Mitchell
PERSON
Michael Cohen
PERSON
Michael Jackson
PERSON
Prince Andrew
PERSON
Julie K. Brown
PERSONOrena
PERSONStroh
PERSON