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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 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 43 of 91 43 k7e2MaxC kjc I do want to n something the court sai government is dribbling ote, before [ go further, to pick up on d. We have a proceeding now where the out facts or what they claim are facts that they could have and should have put in their opening memorandum so we would in writing before the c to proceed, your Honor, that out. Each -—- THE COURT: Bu have had an opportunity to address them ourt. That's not how this is supposed and I thank your Honor for pointing t, Mr. Cohen, please, by all means, you have had the reply in t he time that I have as well. You shouldn't hesitate to respond to any of those facts now. MR. COHEN: appreciate that, your Honor, and I'm going to proceed by pro to submit something in writing, but done, we were deprived also want to media and now the gover close family, with exte er. I would have preferred to be able obviously the way it was of that chance. make clear that our client is not Epstein. She is not the monster that has been portrayed by the nment. She is part of a very large and nsive familial relations, extensive friendships, extensive these folks are on the your Honor, for making which is something one professional relationships. Many of call today, your Honor, and thank you, that availabl would normal] le, though not identified, ly do in a traditional bail hearing, because of the very real concern that they have and our client has about he vr safety and about her privacy and her SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00001920