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be N Ww ws Oo OY ~] oO Ke) Ww a OY 20 21 22 23 24 25 Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 52 of 91 k7e2MaxC kjc appealed by strict conditions. this area, but that's something, government further verification, the government; did not address. the conditions that we have prof safety and confidentiality, keep the proceeding open, decision of And if the court, your Honor, fered are D2 release on That is how the law works and comes out in that the the court determines that Ficient or need insuf as long as we can have some assurance of we would recommend that the court and we should be able to get whatever papers. Let me now, because I have to, put out before your Honor in, of course, let me respond to some of the allegations made time in the reply brief the court needs to satisi y it. trying to spin look sinister to your Honor. Here is fact one: She is a risk of has been hiding out. Well, let's think about this. been litigating civil of ld the country since 2015, your Honor, Mr. Epstein. somebody who is looking to people who spoke before your Honor is a plaintiff those lawsuits seeking millions of We submit, So that's the legal analysis that was absent in the government's presentation today and its because this has been a public proceeding, first for the facts to make my client Flight because she denying, as she does here b She has cases in this courthouse and other parts for that she did anything improper with regards to your Honor, that is the opposite of flee. And in fact, one of the in one of dollars from our client and SOUTHERN STR CT (212) 805-0300 REPORTERS, P.C. DOJ-OGR-00001929