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Case 1:19-cr-00490-RMB Document 36 53 Filed 07/24/19 Page 53 of 74 1 someone with more. 2 I think in the First Amendment common law it would be 3 a judicial document of importance to explain a judicial 4 decision. 5 However, there are countervailing weights, not only 6 the bail, the pretrial statute and its confidentiality but also 7 that we are facing a trial some day. And I know it's early, 8 but there's an enormous amount of publicity, and every fact 9 that is generated by this proceeding becomes the bases of an 10 enormous amount of articles. 11 It's one thing to say Mr. Epstein is wealthy. That's 12 a kind of generic. It's another thing to be chasing down 13 values and accounts. And for that reason, we ask the Court not 14 to publish it unless it's a predicate for your Honor's release 15 decision. 16 And, similarly, if the government is to give you a 17 sample of the seizures, we would make the same request, that 18 this may b vidence some day and that it's the kind of 19 evidence that would burden his future right to a fair and 20 impartial jury in the Manhattan venue. 21 Judge, unless there are other questions, I would just 22 conclude by saying that in my many years at the bar, I've read 23 many detention requests and I've heard many detention 24 arguments. 25 Mr. Rossmiller writes eloquently and speaks SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00000563