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SOUTHERN DISTRICT REPORTERS, P.C.

(212) 805-0300

I188SCHC

(Case called)

THE DEPUTY CLERK: Counsel for the government, please

state your appearance.

MR. LAROCHE: Good afternoon, your Honor. Matt

Laroche and Sid Kamaraju for the government. With us at

counsel table is David Donaldson and Evan Schlessinger from the

FBI, and also John Moscato from pretrial services.

THE COURT: Thank you for coming.

MR. KAPLAN: Good afternoon, your Honor. Jacob Kaplan

for Mr. Schulte.

THE COURT: Mr. Kaplan.

Mr. Schulte, how are you?

I understand, Mr. Kaplan, you have an application.

MR. KAPLAN: Yes, your Honor.

THE COURT: Go ahead.

MR. KAPL AN: Judge, on the last court date , when we

left, the idea was that we had consented to detention with the

understanding that Mr. Schulte would be sent down to Virginia

to face charges based on a Virginia warrant. None of that

happened. Virginia never came to get him. Virginia just

didn't do anything in this case. But before I add ress the bail

issues, I think it's important that this Court hear the full

story of how we actually get here.

At one of the previous court appearances, I believe it

was the November 8th date, this Court asked why the defense

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