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Case 1:19-cr-00490-RMB Document 38 Filed 07/25/19 Page 3of9
Case 1:19-cr-00490-RMB Document 37-1 Filed 07/25/19 Page 3 of 9
e) May be shown to, but not disseminated to or
provided copies of to, prosp
Case 1:19-cr-00490-RMB Document 38 Filed 07/25/19 Page 2 of 9
Case 1:19-cr-00490-RMB Document 37-1 Filed 07/25/19 Page 2 of 9
WHEREAS the defendant, through his counsel, consents
to the entry of this
Case 1:19-cr-00490-RMB Document 37-1 Filed 07/25/19 Page 7 of9
c) Shall not be possessed outside the presence
of Defense Counsel, or maintained, by the Defendant;
d) Shall be made available for insp
Case 1:19-cr-00490-RMB Document 37-1 Filed 07/25/19 Page 6of9
necessary by defense counsel, for trial preparation, and after
defense counsel and/or Defense Staff instructs such
individual(s) of the t
Case 1:19-cr-00490-RMB Document 37-1 Filed 07/25/19 Page 8of9
including but not limited to Confidential Information, within 30
days of the expiration of the period for direct appeal from any
verdict
Case 1:19-cr-00490-RMB Document 37-1 Filed 07/25/19 Page5of9
other identifying designation, are deemed “Confidential
Information.”
is Confidential Information may contain personal
identification inf
Case 1:19-cr-00490-RMB Document 37-1 Filed 07/25/19 Page4of9
disclosing or disseminating the identity of any victims or
witnesses referenced in the Discovery. This Order does not
prohibit Defense Cou
Case 1:19-cr-00490-RMB Document 37-1 Filed 07/25/19 Page 3of9
e) May be shown to, but not disseminated to or
provided copies of to, prospective witnesses and their counsel
(collectively, “Potential W
Case 1:19-cr-00490-RMB Document 37-1 Filed 07/25/19 Page 2of9
WHEREAS the defendant, through his counsel, consents
to the entry of this Order;
IT HEREBY IS ORDERED:
al The Discovery disclosed to th
Case 1:19-cr-00490-RMB Document36 _ Filed 07/24/19 Page 74 of 74 Ta
1 of the Crime Victims' Rights Act and the rights of the victims,
2 particularly the way in which they're being treated in this
3 p
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Case 1:19-cr-00490-RMB Document 36
MS.
TH
oD
GQ
By
and last name.
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Case 1:19-cr-00490-RMB Document36_ Filed 07/24/19 Page 71 of 74 car
proceeding against him pending, but we had a case pending
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Case 1:19-cr-00490-RMB Document 36
them, but that's not something that we'
publicly.
Case 1:19-cr-00490-RMB Document 36
Filed 07/24/19
Page 69 of 74
69
1 directly.
2 MR. WEINBERG: I'd rather you ask him, your Honor.
3 Thank you.
4 THE COURT: Then we'll get to Mr. Boies.
5 By t
Case 1:19-cr-00490-RMB Document 36
1 case.
2 Second, there's an inherent contradiction between the
3 government's tying these two payments by Mr. Epstein in
4 November and early December of 2018 to
ay
Case 1:19-cr-00490-RMB Document 36
Mr. Boies?
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MR. BOIES:
THE COURT:
until we finish with
Yes
Case 1:19-cr-00490-RMB Document 36
Filed 07/24/19
Page 66 of 74
66
Fendant thought he'd
t its money
the covert
and the
to have the defendant
And neither did anyone else
and it
was concerned
Case 1:19-cr-00490-RMB Document36- Filed 07/24/19 Page 64 of 74 64
1 Here's how we know that it's not the case that someone
2 who doesn't commit a crime for 15 years, if that is the case
3 here, but
Case 1:19-cr-00490-RMB Document 36
Filed 07/24/19
Page 61 of 74 61
1 5:00. That's no problem.
2 THE COURT: Fair enough.
3 MR. ROSSMILLER: can't say whether we will, but
4 we'll certainly re-exam
Case 1:19-cr-00490-RMB Document 36
Filed 07/24/19
Page 60 of 74 60
1 presumed innocent people in jail, whether it's Rikers Island or
2 the MCC.
5 again passionately urge your Honor to consider
4
Case 1:19-cr-00490-RMB
Document 36 Filed 07/24/19 Page 59 of 74
59
ad
lity
a
on
1 MR. WEINBERG: I do understand, but it's the
2 complexity and the magnitude of the pretrial preparation, not
5 j
Case 1:19-cr-00490-RMB Document36 _ Filed 07/24/19
Page 58 of 74
58
1 more so than someone who is educated and privileged, and they
2 might need it more.
5 I think everybody has the same right, but
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
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Case 1:19-cr-00490-RMB Document 36
bracelet.
THE
COURT:
It's just a head start.
Filed 07/24/19
Page 56 of 74
[ was going to ask about that.
be
NO
Case 1:19-cr-00490-RMB Document 36
eloquently.
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including this one,
and extraordinary danger and
the set of
Madoff
called th
ay
Case 1:19-cr-00490-RMB Document36_ Filed 07/24/19 Page 55 of 74 a3
Mr. Epstein's compliance and not fleeing an almost elaboratory
2 setting where in 2004, 2005, 2006, and 2007, Mr. Epstein was
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 jud
Case 1:19-cr-00490-RMB Docu
ment 36 Filed 07/24/19 Page 52 of 74 22
1 not appropriate, despite all of the conditions that we argue
2 provide a compelling basis for both safety and appearance, that
Case 1:19-cr-00490-RMB Document 36
Filed 07/24/19
Page 50 of 74
50
1 to those that are offered.
2 So let me be as clear as can.
3 THE COURT: You might as well know what I'm thinking.
4 So respec
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Case 1:19-cr-00490-RMB Document 36
conditions, along wit
home detention, monit
approved by pretrial,
than sufficient to abate an
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Case 1:19-cr-00490-RMB Document36 _ Filed 07/24/19
that your Honor has clear and convincing proof
Mr.
Factor that if
less the
Case 1:19-cr-00490-RMB Document36_ Filed 07/24/19 Page 46 of 74 46
1 Attorney's Office. So Lanna Belohlavek who was the head of the
2 sex offender unit of Mr. Kirshner's state attorney's office.
5 M
Case 1:19-cr-00490-RMB Document 36
Filed 07/24/19
Page 47 of 74 a7
1 constitute the predicate of detention and the predicate —--
2 THE COURT: The $250,000 and the $100,000?
3 MR. WEINBERG: Yes, y
Case 1:19-cr-00490-RMB Document36 _ Filed 07/24/19 Page 45 of 74 one
1 thought I read in all of these papers somewhere that New Mexico
2 was examining its decision that he needn't be registered in
3
ay
Case 1:19-cr-00490-RMB Document 36 Filed 07/24/19 Page 44 of 74
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probation or community control part of the
sentence, he tasked l
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Case 1:19-cr-00490-RMB Document 36
There has been no notice to his
he has done everything in his power to met
these multiple re
ay
Case 1:19-cr-00490-RMB Document36_ Filed 07/24/19 Page 41 of 74 il.
in terms of the registrant's obligations to appear or submit
NO
reports or whatever?
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Case 1:19-cr-00490-RMB Document 36
with the mandates,
court's bail
Three,
the que
ay
Case 1:19-cr-00490-RMB Document36 _ Filed 07/24/19 Page 40 of 74 a0
time I would
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Case 1:19-cr-00490-RMB Document 36
Filed 07/24/19
Page 39 of 74
39
1 The prosecutor, the DA's office, and the defense
2 joining together in making such an application is very unusual
3 [ think is
Case 1:19-cr-00490-RMB Document 36
38
Filed 07/24/19 Page 38 of 74
1 had presented in the state of Florida that talked about other
2 allegations leading to the tier three classification.
3 New Me
Case 1:19-cr-00490-RMB Document36_ Filed 07/24/19 Page 37 of 74 27
1 of attention by the FB
2 He didn't flee. This was all before the NPA while he
3 was facing the very same 1591 and even additiona
ay
Case 1:19-cr-00490-RMB Document 36
recidivism is not
of
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conduct anymore. I
say.
always that,
t's more of
But they measur
r
Case 1:19-cr-00490-RMB Document 36
Filed 07/24/19
Page 33 of 74 dios
1 don't find any case where that says 14 years, and it's over or
2 it evaporates, etc.
3 The argument though is that 14 years o
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Case 1:19-cr-00490-RMB Document36_ Filed 07/24/19 Page 32 of 74 a2
being investigated, he wasn't a predator that couldn't control
his con
Case 1:19-cr-00490-RMB Document
36 =~ Filed 07/24/19
Page 31
of 74 31
1 risk, that would suffice.
2 MR. WEINBERG: think I have to bear the burden of
5 rebutting the presumption as to each prong,
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Case 1:19-cr-00490-RMB Document36 _ Filed 07/24/19 Page 30 of 74 30
THE COURT: Is th
Case 1:19-cr-00490-RMB Document 36
1 know 1£ there are mor 12 cases, all of which involve a
2 minor victim -- kidnapping, sex trafficking of children,
3 aggravated sexual abuse, sexual abuse, offen
Case 1:19-cr-00490-RMB Document 36
Filed 07/24/19
Page 28 of 74
28
those
out
.
the Congress in 1984,
for release,
—- "any
the presumption,
would be
the court and
that they could be
, the
Case 1:19-cr-00490-RMB Document 36
Filed 07/24/19
Page 24 of 74
24
t this
cterstate
prosecution.
the
division and
tion Unit.
was not squarely
that some
There are submissions
1 She receive