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be N Ww ws Oo OY ~] oO Ke) Ww _ OY 20 21 22 28 24 25 Case 1:19-cr-00490-RMB Document36 _ Filed 07/24/19 that your Honor has clear and convincing proof Mr. Factor that if less the predictive under the kind of combination of conditions, his risk of influencing adversely a witness, Page 48 of 74 occurred, much Epstein was released there would be now that there That would be self-des fed) federal prosecution. tructive. It 48 any is would constitute a crime with a nexus to what require. But the conditions also, your Honor, radically the statutes for home deten Limit we've asked your Honor tion, and I will get to the monetary conditions and the risk of Flight ina moment. We've asked for home detention. visiting list to be approved by pretrial, We've asked meaning almost nobody for the except Mr. Weingarten and myself, Mr. Fernich, defense team. lawyers on our We would rip out the cell phones. There is one line. We consent to the monitoring of that line. We consent to the waiver of search and seizure. These are the conditions that have been accepted and, again, not always, Judge. There are detention orders. I'm a Boston lawyer. remember arguing before the Former Chief Judge Mark Wolf on behalf of a defendant who was arrested about two months after an induction ceremony for organized crime about 20 years ago. And Judge Wolf found that along with financial SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00000558