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be N Ww ws Oo OY ~] oO Ke) a fan) = be N Ww = Hs Oo a OY a ~] a oO a Ke) 20 21 22 23 24 25 Case 21-770, Document 20-2, 04/01/2021, 3068530, Page115 of 200 52 k7e2MaxC kjc appealed by the government; decision of the court, release on strict conditions. That is how the law works and comes out in this area, but that's something ld your Honor , that the government did not address. And if the court determines that the conditions that we have prof fered are insufficient or need further verification, as long as we can have some assurance of safety and confidentiality, we would recommend that the court the court needs to satisfy it. papers. Let me now, because that was absent in the government's presen I have to, keep the proceeding open, and we should be able to get whatever So that's the legal analysis put out before your Honor in, o tation today and its because this has been course, a public proceeding, let me respond to some of the allegations made for the first time in the reply brief, trying to spin look sinister to your Honor. Here is fact one: She is a risk of facts to make my client Flight because she has been hiding out. Well, let's think about this. She has been litigating civil cases in this courthouse and other parts of the country since 2015, denying, as she does here befor your Honor, that she did anything improper with regards to Mr. Epstein. We submit, your Honor, somebody who is looking to flee people who spoke before your Honor is a plaintiff in one of that is the opposite of And in fact, one of the those lawsuits seeking millions of dollars from our client and SOUTHERN DISTRICT REPORTERS, (212) 8 05-0300 P a Gs DOJ-OGR-00001056