"He would have to travel for at least three hours to get to any exit port, which would give the authorities plenty of time to respond."
Michaels would stay in the Waikato town of Otorohonga - understood to be where his girlfriend lives.
"Mr Michaels would be in a small town, he would be known to the police - the focus would be very much on him," Mr Kaye said.
He also submitted that Michaels was in poor health, suffering from heart ailments, and had been unable to see a specialist cardiologist while in custody in Auckland's Mt Eden Corrections Facility.
It would also be very difficult for him to prepare his defence from behind prison walls, and to have adequate access to his lawyer.
Crown prosecutor Rachel Reed said it was not unusual for defendants to prepare for complex trials from jail, and it would be no easier for Michaels to see his lawyer if he was staying in Otorohanga, some two to three hours from Auckland.
With regard to Michaels' health, Ms Reed submitted that the prisoner could receive whatever treatment necessary while in jail, but Michaels had refused it when offered.
He had in fact seen the prison doctor: "He walked into the consulting room while (the doctor) was seeing another prisoner. The doctor told him to wait outside and Mr Michael's took offence and refused to participate further," Ms Reed said.
He had also at one time told a prison authority that he would only see a doctor "if his lawyer advised it".
Prison staff suspected he was exploiting his health situation in order to get bail, Ms Reed said.
Justice Kos agreed with an earlier Auckland District Court decision that Michaels was "a particularly resourceful man" and was a flight risk.
This was evidenced by his failure to return to New Zealand when granted permission to travel Australia to see his sick mother: "He was having a high old time in Queensland, leaving granny alone in Victoria," Justice Kos said.
There was also the risk that Michaels would obtain a false passport, which would make it very difficult for border authorities to stop him leaving the country.
"He could travel overseas by aircraft, vessel, or quite simply abscond - go bush - most likely to Queenstown, that sort of bush."
The SFO case is that Michaels persuaded two Christchurch casino executives to invest more than $2.8 million in a make-believe takeover of Auckland's SkyCity casino.
He also allegedly used rugby superstar Jonah Lomu's name to get more than $350,000 from a couple as "security" on a Taupo luxury apartment sale which fell through.
Michaels is scheduled to stand trial for eight weeks in October.
