DOJ-OGR-00019990.pdf

Case 21-58, Document 39-2, 04/01/2021, 3068530, Page131 of 200 1 investigations. There is the investigation of our client and 2 there is the investigation of Mr. Epstein. And they are, in 3 the government's words, in our words together, voluminous 4 materials. We haven't seen any of it yet, but voluminous, 5 including voluminous electronic materials. The notion that we 6 would be able to in any meaningful way review these with our 7 client to prepare the case for motion and for trial under the 8 current pandemic situation is just not realistic. It is not 9 meaningful. It is not fair. And I should say, as your Honor 10 noted, in the Stephens case, we are not faulting the Bureau of 11 Prisons. We are not faulting the Marshal Service. We 12 understand they are doing the best they can under the 13 circumstances. But this is just not realistic. We have 14 conduct that's alleged to be 25 years old. You have extensive 15 discovery that's going to take the government, if they hit the 16 deadlines your Honor set -- and we all know that sometimes it 17 doesn't happen -- four and a half months to provide, and the 18 government wants our client to remain in custody that whole 19 time, without being able to meet with us in person, with 20 limited access in some form of administrative seg., apparently 21 because they are afraid of what happened with Mr. Epstein, I 22 don't know, and it is just not a realistic way to prepare a 23 case, particularly, your Honor, when, as we submit, the 24 conditions and combination of conditions to secure her release 25 can be satisfied here under your Honor's guidance. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00019990