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single other court. Additionally, other cases in this Circuit and elsewhere have upheld convictions of procurers or customers. See United States v. O'Connor, 650 F.3d 839 (2d Cir. 2011) (upholding convictions under Section 1591 of both the buyer and seller of a child); United States v. Cook, 782 F.3d 983
, serious charges, and the prospect of a lengthy prison sentence, the defendant proposes to be released on conditions that are woefully inadequate. The Release Motion misconstrues and misunderstands the relevant EFTA00100380 Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 2 of 14 Honorable Richard M. Ber
single other court. Additionally, other cases in this Circuit and elsewhere have upheld convictions of procurers or customers. See United States v. O'Connor, 650 F.3d 839 (2d Cir. 2011) (upholding convictions under Section 1591 of both the buyer and seller of a child); United States v. Cook, 782 F.3d 983
, serious charges, and the prospect of a lengthy prison sentence, the defendant proposes to be released on conditions that are woefully inadequate. The Release Motion misconstrues and misunderstands the relevant EFTA00105478 Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 2 of 14 Honorable Richard M. Ber
single other court. Additionally, other cases in this Circuit and elsewhere have upheld convictions of procurers or customers. See United States v. O'Connor, 650 F.3d 839 (2d Cir. 2011) (upholding convictions under Section 1591 of both the buyer and seller of a child); United States v. Cook, 782 F.3d 983
, serious charges, and the prospect of a lengthy prison sentence, the defendant proposes to be released on conditions that are woefully inadequate. The Release Motion misconstrues and misunderstands the relevant EFTA00058455 Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 2 of 14 Honorable Richard M. Ber
single other court. Additionally, other cases in this Circuit and elsewhere have upheld convictions of procurers or customers. See United States v. O'Connor, 650 F.3d 839 (2d Cir. 2011) (upholding convictions under Section 1591 of both the buyer and seller of a child); United States v. Cook, 782 F.3d 983
, serious charges, and the prospect of a lengthy prison sentence, the defendant proposes to be released on conditions that are woefully inadequate. The Release Motion misconstrues and misunderstands the relevant EFTA00068050 Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 2 of 14 Honorable Richard M. Ber
single other court. Additionally, other cases in this Circuit and elsewhere have upheld convictions of procurers or customers. See United States v. O'Connor, 650 F.3d 839 (2d Cir. 2011) (upholding convictions under Section 1591 of both the buyer and seller of a child); United States v. Cook, 782 F.3d 983
, serious charges, and the prospect of a lengthy prison sentence, the defendant proposes to be released on conditions that are woefully inadequate. The Release Motion misconstrues and misunderstands the relevant EFTA00071674 Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 2 of 14 Honorable Richard M. Ber
single other court. Additionally, other cases in this Circuit and elsewhere have upheld convictions of procurers or customers. See United States v. O'Connor, 650 F.3d 839 (2d Cir. 2011) (upholding convictions under Section 1591 of both the buyer and seller of a child); United States v. Cook, 782 F.3d 983
, serious charges, and the prospect of a lengthy prison sentence, the defendant proposes to be released on conditions that are woefully inadequate. The Release Motion misconstrues and misunderstands the relevant EFTA00076303 Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 2 of 14 Honorable Richard M. Ber
single other court. Additionally, other cases in this Circuit and elsewhere have upheld convictions of procurers or customers. See United States v. O'Connor, 650 F.3d 839 (2d Cir. 2011) (upholding convictions under Section 1591 of both the buyer and seller of a child); United States v. Cook, 782 F.3d 983
, serious charges, and the prospect of a lengthy prison sentence, the defendant proposes to be released on conditions that are woefully inadequate. The Release Motion misconstrues and misunderstands the relevant EFTA00076331 Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 2 of 14 Honorable Richard M. Ber
single other court. Additionally, other cases in this Circuit and elsewhere have upheld convictions of procurers or customers. See United States v. O'Connor, 650 F.3d 839 (2d Cir. 2011) (upholding convictions under Section 1591 of both the buyer and seller of a child); United States v. Cook, 782 F.3d 983
, serious charges, and the prospect of a lengthy prison sentence, the defendant proposes to be released on conditions that are woefully inadequate. The Release Motion misconstrues and misunderstands the relevant EFTA00076359 Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 2 of 14 Honorable Richard M. Ber
single other court. Additionally, other cases in this Circuit and elsewhere have upheld convictions of procurers or customers. See United States v. O'Connor, 650 F.3d 839 (2d Cir. 2011) (upholding convictions under Section 1591 of both the buyer and seller of a child); United States v. Cook, 782 F.3d 983
, serious charges, and the prospect of a lengthy prison sentence, the defendant proposes to be released on conditions that are woefully inadequate. The Release Motion misconstrues and misunderstands the relevant EFTA00078231 Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 2 of 14 Honorable Richard M. Ber
single other court. Additionally, other cases in this Circuit and elsewhere have upheld convictions of procurers or customers. See United States v. O'Connor, 650 F.3d 839 (2d Cir. 2011) (upholding convictions under Section 1591 of both the buyer and seller of a child); United States v. Cook, 782 F.3d 983
, serious charges, and the prospect of a lengthy prison sentence, the defendant proposes to be released on conditions that are woefully inadequate. The Release Motion misconstrues and misunderstands the relevant EFTA00080486 Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 2 of 14 Honorable Richard M. Ber
Entities connected to both O'Connor and The Release Motion

Jeffrey Epstein
PERSON
United States
LOCATION
Julie K. Brown
PERSON
New York
LOCATION
Department of Justice
ORGANIZATIONEmmy Taylor
PERSON
Prince Andrew
PERSON
Michael Jackson
PERSONthe Southern District
LOCATIONFBI
ORGANIZATION
Ghislaine Maxwell
PERSON
Michael Cohen
PERSON
George Mitchell
PERSONMartin Weinberg
PERSON
Alexander Acosta
PERSON
Anderson
PERSON
U.S. Virgin Islands
LOCATION
Geoffrey S. Berman
PERSON
Harry Reid
PERSONMorrison
PERSON