DOJ-OGR-00000616.pdf

--- Page 1 --- **Document Header** * Case 1:19-cr-00490-RMB * Document 42 * Filed 08/06/19 * Page 5 of 10 **Case Text** imprecise. Labor Day 2020 or immediately thereafter. And I make that recommendation -- we haven't received the discovery yet. Understandably, it is coming, and I'm not in any way contesting that there has been a delay, but we haven't had an opportunity to start reviewing what the government has predicted to be over a million pages of discovery with Mr. Epstein and to assess Mr. Epstein's ability to exercise his constitutional right, while at MCC, in assisting counsel prepare for a very difficult case that addresses events that it is alleged occurred 14 to 17 years ago. THE COURT: Okay. MR. WEINBERG: So, we need time to receive a million pages of discovery and to prepare to defend a four- to six-week trial, when a lot of the immediate attention is going to be on the very unique and complex constitutional issues connected to the nonprosecution agreement, our contention that the government's allegations are inextricably intertwined and constitutionally barred by the NPA. There are double jeopardy issues both connected to the conspiracy count, which looks to be an overlap with one of the charges that was expressly within the immunity provisions in the NPA. We are going to be spending a lot of time, and that's why I agreed with the government that we should make early discovery motions on the NPA-related issues, on double-jeopardy-related issues, so that we could not only facially brief the motion to dismiss, but **Footer** SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 **Case Number** DOJ-OGR-00000616