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Case 1:19-cr-00490-RMB Document36_ Filed 07/24/19 Page 37 of 74 27 1 of attention by the FB 2 He didn't flee. This was all before the NPA while he 3 was facing the very same 1591 and even additional statutes that 4 carried additional potential federal penalties, interstate 5 travel, interstate communications. 6 Again, we have to infer from the past what the future 7 conduct would be. I think it's important that he hired lawyers 8 to defend him. He didn't run away. 9 Despite the fact there was no bail, no conditions, he 10 didn't have the publicity he has now, he could have, if he was 11 a fleer, left at that time and done what the government fears 12 he would do today if released under an enormous set of 13 conditions that I will ask to supplement. 14 Two is the next period was the NPA period. Again, he 15 signed up to go to state jail, county jail. He went to county 16 jail. He got out in 2010. He was subject to the 17 registrations. 18 And if I can go back in to try and answer your Honor's 19 questions on registration. He has not reapplied challenging 20 the New York Appellate Division or the New York Supreme Court 21 decision. 22 There was a legal dispute. Mr. Epstein's counsel at 23 the time believed that the classification in New York should be 24 restricted to the offense of conviction. And the Court 25 determined that it would rely instead on an affidavit that it SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00000547