DOJ-OGR-00000659.jpg

be N Ww ws Oo OY ~] oO WO a oO = be N Ww Case 1:19-cr-00490-RMB Document 53 J8RSEPS1 reasons, your Honor. One is the timing of Mr. August 10. On August 12, being filed in the Second Circuit. Filed 09/03/19 United States A have communications between the Southern for the preservat facilitated and Northern Distrrvet. Gf Epstein's demise. Page 21 of 86 a bail pending appeal motion was tion and production of furthered our ef Georgia, £ the Southern @) District of On August ttorneys were going to respond Forts 12 or 13, the to our request F documen ts that would to demonstrate District the f Florida, which was standing in the shoes Southern discharging our responsibilities. videnc Oo a OY a ~] a oO a Ke) 20 21 22 23 24 25 minor after 2005. prosecution was squarely within the heartland of NPA. futile, Third, Honor had scheduled. commit suicide on August 10, motion is being In other that Mr. We had a signii you know, District. words, Florida main justice and the we were beginning the process Epstein had committed any of The subject matter of Ficant mo ion to dismiss. defeatist a ttitude. There had been no new fense against a the New York the Florida This was not a we had all the discovery motions that your Second lf So the timing we had an independen for a pretrial at the autopsy which occurred on August 11. city medical examiner's findings were inconclusive. SOUTHERN D STR CT RE (212) 805-0300 On August 11, PORTERS, P. when his bail pending appeal t doctor who was present We are 21 It was on detainee to filed on August 12, strikes us as implausible. the DOJ-OGR-00000659