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fe N Ww ws Oo OY ~] oO Ke) a oO a fe N Ww fe ws Oo _ OY a ~] a oO a Ke) 20 21 22 28 24 25 Case 1:19-cr-00490-RMB Document 36 Filed 07/24/19 Page 65 of 74 65 would have been charged is particularly rich in this case. There are plumes of the Court can reasonably infer that there is generous to his old not credible, de Court to risk the safety of The idea that Mr. Herald published a series of the circumstances leading Finally and most importantly, fendant has discip sel f—-discipl pre ference lined himself, this idea that the the community on the ine of a man they appear to concede has a for underaged girls. fF smoke as to those particular issues, and fire. Epstein was feeling particularly friends and associates days after the Miami articles about his misconduct and to his non-prosecution agreement is and the Court shouldn't find it to be credible. the defendant is asking the concession that the def appetite This idea that for children. on himself the elements of discip] ine himselt here. They concede that the government will be able to show has before. They say that he didn't he has disciplined himself endant has a problem, Your Honor, the crime. They concede that he has to the defendant is a that he has an keeps telling fl F to avoid committing the types of crimes he becaus there was the potential he would be -- didn't £1] despite th potential l to be charged fact that he thought there was a I'm sorry. he thought that They say he SOUTHERN D STR CT R G iPORT (212) 805-0300 ERS, P. DOJ-OGR-00000575