Case 1:08-cr-20612-PAS
Document 44-2
Entered on FLSD Docket 07/29/2008
Page 13 of 20
He takes complete care of me. I cannot function without him. He takes care of everything when I am bed stricken which, unfortunately, happens often." Judge, I believe sincerely in addition to the four and a half million dollars from his family, he has two properties, two homes that he owns that has approximately $240,000 worth of equity. He would be willing to pledge those. In addition, we would be willing to offer a $100,000 corporate surety bond, in addition, and also renew our offer to close that business down under the government's supervision. I will be happy, if the court releases him, to fly to California and be present along with any government agents to supervise the closing of that business. In addition, I would ask the court to place him on a GPS monitoring system, eliminate all computers from his home, and to require that he get gainful employment in a field that is not aviation related. The allegations I believe are a little all over the place at this point. I believe once the government reviews these thousands and thousands of e-mails, I think things may clarify. My client, I believe, may have made a mistake by selling items that were ultimately exported without a license, but I don't believe the evidence will show that he intentionally tried to circumvent the embargo, and I hope that that will come up once the government reviews all of the e-mails. I would ask the court to please consider a release of my client based on any or all or a combination of the conditions that I have set forth. Thank you. THE COURT: Okay. Mr. Lyons. MR. LYONS: Why don't we go through the last first, and since counsel, both counsel have talked about the problem cause aspects of this case, we suffer somewhat of a disadvantage, in that there are about 800 e-mails that go back and forth over a period of time between my client and Mr. Keshari, but I note that in the beginning, and I guess it is sort of like when my wife goes looking for goods, and she will go to Dania and buy antiques, I look at it as junk and she looks at it as an antique. I guess it is in the eyes of the beholder. The materials that were in his house -THE COURT: Your antiques are someone else's junk. That is what I tell my wife. MR. LYONS: Yes. I say that except for when she buys clothes and, unfortunately, that's another problem, but realistically, Your Honor, in this case the materials that were found in his house, the boxes of parts that they refer to are not air-worthy parts. They were sitting in his backyard. I only wish they were worth the kind of money they were worth, but we can sit here and speculate at this point. In looking at the case, you are talking about four sets of parts. I know that the first transaction was not with Mr. Keshari and my client, but was with someone else in either Dade or Broward County that relates to a gyro. I don't know anything about the gyro. I don't know whether that person was arrested. It has nothing to do with my client. I don't even know why it is in the probable cause affidavit, but having said that, Your Honor, let's look at my client at this point. We will deal with the other issues at a later date. I am sort of at a disadvantage, since I don't have any Jencks or any of the materials. Here is a guy who left Communism, who left Romania. They confiscated his land in Romania. His parents, he, his sister, both sisters came here to the United States in