DOJ-OGR-00019990.pdf

--- Page 1 --- The extracted text is: **Header:** Case 21-58, Document 39-2, 04/01/2021, 3068530, Page131 of 200 **Footer:** SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00019990 **Page Number:** 68 **Text:** investigations. There is the investigation of our client and there is the investigation of Mr. Epstein. And they are, in the government's words, in our words together, voluminous materials. We haven't seen any of it yet, but voluminous, including voluminous electronic materials. The notion that we would be able to in any meaningful way review these with our client to prepare the case for motion and for trial under the current pandemic situation is just not realistic. It is not meaningful. It is not fair. And I should say, as your Honor noted, in the Stephens case, we are not faulting the Bureau of Prisons. We are not faulting the Marshal Service. We understand they are doing the best they can under the circumstances. But this is just not realistic. We have conduct that's alleged to be 25 years old. You have extensive discovery that's going to take the government, if they hit the deadlines your Honor set -- and we all know that sometimes it doesn't happen -- four and a half months to provide, and the government wants our client to remain in custody that whole time, without being able to meet with us in person, with limited access in some form of administrative seg., apparently because they are afraid of what happened with Mr. Epstein, I don't know, and it is just not a realistic way to prepare a case, particularly, your Honor, when, as we submit, the conditions and combination of conditions to secure her release can be satisfied here under your Honor's guidance.