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Case 1:17-cr-00330-AJN Document 1002 Filed 02/18/20 Page 31 of 36

(Tr. 87). Following the analysis the Court has already conducted, several of the cases cited by the defendant are readily distinguishable. See, e.g., United States v. Khashoggi, 717 F. Supp. 1048, 1050-52 (S.D.N.Y. 1989) (in ordering defendant released pending trial, noting, among other things, that the defendant not only waived his right to appeal extradition in Switzerland, but that he traveled immediately to the United States for arraignment, and that his country’s Government committed to ensuring his appearance at trial); United States v. Bodmer, No. 03 Cr. 947 (SAS), 2004 WL 169790, at *1, *3 (S.D.N.Y. June 28, 2004) (setting conditions of bail where defendant arrested abroad had already consented to extradition to the United States and finding that the Government—whose argument was “based, in large part, on speculation” as to the defendant’s financial resources—had “failed to meet its burden”). And there is support in the case law for detaining individuals in comparable situations to the defendant. See, e.g., United States v. Boustani, 356 F. Supp. 3d 246, 252-55 (E.D.N.Y.), aff’d, No. 19-344, 2019 WL 2070656 (2d Cir. Mar. 7, 2019) (ordering defendant detained pending trial and finding that defendant posed a risk of flight based on several factors, including seriousness of the charged offenses, lengthy possible sentence, strength of Government’s evidence, access to substantial financial resources, frequent international travel, “minimal” ties to the United States, and “extensive ties to foreign countries without extradition”); United States v. Patrick Ho, 17 Cr. 779 (KBF), Dkt. 49 (S.D.N.Y. Feb. 4, 2018) (ordering defendant detained based on defendant’s risk of flight and citing the strength of the Government’s evidence, lack of meaningful community ties, and “potential ties in foreign jurisdictions”); United States v. Epstein, 155 F. Supp. 2d 323, 324-326 (E.D. Pa. 2001) (finding that defendant’s dual citizenship in Germany and Brazil, lucrative employment and property interests, and lack of an extradition treaty with Brazil weighed in favor of detention despite the fact that defendant and his wife owned “substantial” property and other significant assets in the

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