DOJ-OGR-00001072.jpg

be N Ww ws Oo OY ~] oO Ke) Ww a OY 20 21 22 23 24 25 Case 21-770, Document 20-2, 04/01/2021, 3068530, Page131 of 200 k7e2MaxC kjc 68 our client and investigations. There is the investigation of 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 Ls It is not meaningf fair. And I should say, as your Honor noted, circumstances. conduct that's alleged discovery that's going deadlines your Honor set Prisons. We are n doesn't happen —— government wants our cl time, without bein limited access in b don' case, conditions and combination of caus t know, in the Stephens case, we are not ot —— and we all know faulting the Marshal understand they are doing the best But this is just not to be 25 years old. to tak four and a half Servic faulting the Bureau of W realistic. You hav t, if the governmen g able to meet with us in person, some form of administrative seg., fraid o they are a and it particularly is jus , your f what happened with Mr. t not a realistic way to Honor, months to provide, they can under the We have xtensiv they hit the that sometimes it and the lient to remain in custody that whole with apparently when, as we submit, Epstein, prepare a the her releas conditions to secur can be satisfied here under your Honor's guidance. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00001072