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Case 1:19-cr-00490-RMB Document 36 Filed 07/24/19 Page 35 of 74 35 state without more 1 that -- by the way, you're suggesting that the measure of 2 recidivism is a reported classic case by the prosecutor, 3 or federal, indictment, etc., etc. 4 That may not even occur in most instances because a 5 lot of cases that ar ven referred to prosecutor offices are 6 never formalized or never brought. 7 So I'm not sure that the passage of time, 8 and without more study and with let's say discipline of a 9 defendant -—- I'm not sure that that gets us there. 10 MR. WEINBERG: I guess I would have two responses. 11 THE COURT: Sure. 12 MR. WEINBERG: One, that the level of publicity 13 brought to Mr. Epstein and brought in this case and even 14 brought before the bringing of this case, his wealth which 15 makes him an attractive civil defendant as well as a criminal 16 defendant -- and there have been a number of complaints or 17 threats or notices or demands by different civil lawyers. 18 But there is an unprecedented amount of publicity that 19 would mobilize and motivate people who were victimized by him. 20 If there were any people victimized by him after 2005, 21 utterly lacking in the average case where some victim doesn't 22 know that they've got an ear, whether it's an ear of 23 bar or an ear of the United States Attorney, to receive, 24 positively receive, and embrace an allegation against 25 Mr. Epstein. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 it is the civil DOJ-OGR-00000545