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Case 1:19-cr-00490-RMB j7v2espC kjc Document 42 Filed 08/06/19 Page 5 of 10 5 1 imprecise. Labor Day 2020 or immediately thereafter. And I 2 make that recommendation -- we haven't received the discovery 3 yet. Understandably, it is coming, and I'm not in any way 4 contesting that there has been a delay, but we haven't had an 5 opportunity to start reviewing what the government has 6 predicted to be over a million pages of discovery with 7 Mr. Epstein and to assess Mr. Epstein's ability to exercise his 8 constitutional right, while at MCC, in assisting counsel 9 prepare for a very difficult case that addresses events that it 10 is alleged occurred 14 to 17 years ago. 11 THE COURT: Okay. 12 MR. WEINBERG: So, we need time to receive a million 13 pages of discovery and to prepare to defend a four- to six-week 14 trial, when a lot of the immediate attention is going to be on 15 the very unique and complex constitutional issues connected to 16 the nonprosecution agreement, our contention that the 17 government's allegations are inextricably intertwined and 18 constitutionally barred by the NPA. There are double jeopardy 19 issues both connected to the conspiracy count, which looks to 20 be an overlap with one of the charges that was expressly within al the immunity provisions in the NPA. We are going to be 22 spending a lot of time, and that's why I agreed with the 23 government that we should make early discovery motions on the 24 NPA-related issues, on double-jeopardy-related issues, so that 25 we could not only facially brief the motion to dismiss, but SOUTH BRN D STR CT RE PORT ERS, (212) 805- 0300 DOJ-OGR-00000616