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and not alleged to have been involved in ongoing criminal activity. To say that there are absolutely no conditions flies in the face of cases where non-United States citizens with no ties to the district, let alone the country, were released on lesser conditions for alleged criminality ongoing up to or within ho
n such extraordinary and restrictive conditions are available would be a miscarriage of justice. Dated: February 23, 2021 Respectfully submitted, Bata C. Swpattn. Bubb' C. Sternheim Law Offices of Bobbi C. Sternheim Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON,
and not alleged to have been involved in ongoing criminal activity. To say that there are absolutely no conditions flies in the face of cases where non-United States citizens with no ties to the district, let alone the country, were released on lesser conditions for alleged criminality ongoing up to or within ho
n such extraordinary and restrictive conditions are available would be a miscarriage of justice. Dated: February 23, 2021 Respectfully submitted, Bata C. Swpattn. Bubb' C. Sternheim Law Offices of Bobbi C. Sternheim Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON,
and not alleged to have been involved in ongoing criminal activity. To say that there are absolutely no conditions flies in the face of cases where non-United States citizens with no ties to the district, let alone the country, were released on lesser conditions for alleged criminality ongoing up to or within ho
n such extraordinary and restrictive conditions are available would be a miscarriage of justice. Dated: February 23, 2021 Respectfully submitted, Bata C. Swpattn. Bubb' C. Sternheim Law Offices of Bobbi C. Sternheim Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON,
Entities connected to both United States and Bata C. Swpattn

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
John F. Kennedy
PERSON
Michael Cohen
PERSON
Richard Kahn
PERSON
United Kingdom
LOCATIONJeffrey Pagliuca
PERSONthe Northern District
LOCATIONCohen & Gresser LLP
ORGANIZATIONPretrial Services
ORGANIZATIONR. Everdell
PERSONMORGAN & FOREMAN
ORGANIZATIONBobbi C. Sternheim
PERSONPetrov
PERSONDuffey
PERSON
Dominique Strauss-Kahn
PERSONWilliam S. Duffey
PERSONthe Personal Account
ORGANIZATIONSelected Asset Monitor
ORGANIZATIONPretrial Motions Raise Substantial Legal
ORGANIZATION