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Wase ba9-cr-00490-RMB Document 18 Filed 07/16/19 Page 6 of 18 6 1 well. That is just to round out the notification that the U.S. 2 Attorney's office has made. 3 MR. WEHEINGARTEN: May I be heard briefly on that? 4 THE COURT: Sure. 5 MR. WEINGARTEN: For us, your Honor, the NPA is the 6 center of the universe for everything, search included, becaus 7 the NPA was the result of an extensive 3-year investigation by 8 law enforcement in Florida. In essence, the Feds made Mr. 9 Epstein plead to a state offense and they declined prosecution 10 federally, and that is translated in the NPA. Mr. Epstein did 11 his time, Mr. Epstein is on the registration list, and Mr. 12 Epstein paid the alleged victims. 13 As am sure you have noted from the indictment, that 14 conduct too is an ancient history. That conduct is 2002 to 15 2005. It is our belief that this is basically a re-do. This 16 is basically the Feds today, not happy with what happened in 17 the decision that led to the NPA, redoing the same conduct that 18 was investigated 10 years ago and calling it, instead of 19 prostitution, calling it sex trafficking. We think that is the 20 heart of everything, and that will be the centerpiece of our 21 defense, at least legally. 22 THE COURT: My understanding of what the government is 28 asserting is that the episodes that occurred in Manhattan were 24 not included in the nonprosecution agreement in Florida and 25 that there is a separate basis not only for a sex trafficking SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR- 00000392