DOJ-OGR-00019964.jpg

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 21-58, Document 39-2, 04/01/2021, 3068530, Page105 of 200 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. 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 discussed earlier in the proceeding, government until November to produce preparing a det and we submit, she i frank Ss trict conditions, Moe. your Honor. Fing schedule. as Thank you very tunity to be heard and also for accommodating We appreciate that, this is a very important proceeding for my we laid out in our Bail Reform Act and related case law, was discussed in the government's she ought to be released on a bail in order to det ly, D crisis, to us, the notion of your Honor. fend a case like this with the extent of discovery which was that's going to take the 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 thless, aimless, sinister in its reply brief and in its presen portray her before the court as a rut person. SOUTHERN DISTRICT REPORTERS, (212) 805-0300 P a Gs DOJ-OGR-00019964