DOJ-OGR-00001919.jpg

be NO Ww ws Oo OY ~] oO Ke} a oO he be No (ee) = Hs Oo _ OY a ~] a oO a Ke} 20 21 22 23 24 25 Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 42 of 91 42 k7e2MaxC kjc THE COURT: Mr. Cohen, MR. COHEN: much for the oppor us with regard to your Honor. Your Honor, client. It is critical Thank you, Ms. Moe. you may proceed. Thank you, the brie papers, that under the none of which, by the way, presentation, package with st And, during the COVI and we submit, Bail Rei Fing schedule. your Honor. she i frank Ss sh in order to det trict conditions, ly, D crisis, your Honor. with the extent of discussed earlier in the proceeding, that's government until November to produce to us, preparing a det We appreciate that, Thank you very tunity to be heard and also for accommodating this is a very important proceeding for my as we laid out in our Form Act and related case law, was discussed in the government's ought to be released on a bail fend a case like this discovery which was going to take the the notion of Fense with our client while she is in custody under these conditions is just not realistic. address a few things. not Jeffrey Epstein, [ would also like to take a moment, your Honor, to As we noted in our papers, our client is and she has been the target of essentially endless media spin that apparently the government has picked up tation today, trying to aimless, sinister in its reply brief and in its presen portray her before the court as a ruthless, person. SOUTHERN DISTRICT REPORTERS, (212) 805-0300 P a Gs DOJ-OGR-00001919