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Case 1:19-cr-00490-RMB Document36_ Filed 07/24/19 Page 5/7 of 74 37 1 reach the decision some day the Second Circuit may have to 2 address about whether or not a wealthy person should be denied 5 release because the private guard condition somehow is more 4 like detention than release. 5 We need him released, Judge. This is an enormously 6 challenging case for his defense counsel. The government is 7 hugely resourced. They've got over a million pages of 8 discovery. 9 He's in the SHU unit. It's not a condition that 10 somebody can defend themself. And Mr. Epstein's goal, like it 11 was before, is to hire counsel to defend him and to work with 12 counsel closely to exercise his presumption of innocence, to 13 defend himself in a principled way in a courtroom, and not to 14 flee. And I would urgently ask your Honor to consider our bail 15 application. 16 THE COURT: I will. 17 MR. WEINBERG: Thank you, Judge. 18 THE COURT: I will consider and reconsider. 19 On that point, I noticed that was the last paragraph 20 think in your letter -- I'll examine that again too -- here is 21 my reaction. I don't know if this is legally sustainable or 22 not. I will look at the cases. 23 You have all these people or have had on Rikers Island 24 who can't make a thousand dollars bail, for example, and they 25 have every right to consult with their lawyer, perhaps even SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00000567