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CasSecdesbe-cr-00490-RMB Document 18 Filed 07/16/19 Page 14 of 18 1a think we addressed that counsel has a defens 1 evaluate that response and see whether in terms of one of ndants in this we don't expect any It certainly is your Honor? ttlesome and Epstein's when they for an appropriate statute that Mr. 1s. There was including obstruction. faith were having discussions back Epstein's 1 MR. ROSSMILLER: Your Honor, 2 in our initial submission. To th xtent 3 response to it, we wil 4 additional submission from the government is required or 5 appropriate. 6 THE COURT: [ think that's it for me 7 questions that I might have had. 8 There is, of course, a conspiracy charge here, 9 the two counts. It may be early in your investigation to know. 10 Do you anticipate that there may be other def 11 proceeding? 12 MR. ROSSMILLER: Your Honor, 13 imminent superseding indictments in this case. 14 possible down the road. 15 MR. WEINGARTEN: May I make one point, 16 These obstruction allegations we find very n 17 bothering. My understanding is that the Feds and Mr. 18 attorneys back in the early 2000s, or 2007 and 8, 19 were negotiating were looking desperately 20 statute. They finally settled on a state 2] Epstein pled to. We all know how unusual that 22 some consideration of a federal statute, 28 So lawyers in good 24 and forth whether or not they could squeeze Mr. 25 conduct into a particular statute, and SOUTHERN D they concluded they STR CT R G (212) ‘PORTERS, P.C. 805-0300 DOJ-OGR-00000400