DOJ-OGR-00001929.jpg
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Case 1:20-cr-00330-AJN Document 93 Filed 12/10/20 Page 52 of 91
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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
Document Details
| Filename | DOJ-OGR-00001929.jpg |
| File Size | 634.5 KB |
| OCR Confidence | 92.9% |
| Has Readable Text | Yes |
| Text Length | 1,712 characters |
| Indexed | 2026-02-03 16:18:12.464063 |