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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 68 of 91 k7e2MaxC kjc investigations. there is the investigation of There is the investigation of 68 our client and the government's words materials. including voluminous electronic materials. would be able to in any meaningful way review client to prepar th current pandemic situation is just Ls It is not meaningf fair. And I should say, Mr. Epstein. And they are, in , in our words together, voluminous We haven't seen any of it yet, but voluminous, The notion that we these with our case for motion and for trial under the not realistic. It is not 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, caus t know, in the Stephens case, we are not ot faulting the Marshal understand they are doing the best But this is just not to be 25 years old. to tak —- and we all know 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, conditions and combination of 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, (212) 805-0300 DOJ-OGR-00001945