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ing those goals in many prominent cases prosecuted in our Circuit, including cases against defendants as infamous as Bernie Madoff, Marc Dreier and David Brooks. To be clear, defense counsel are fully confident Mr. Epstein will appear as required without resort to this measure. And we understand and appreci
unding the practice, we respectfully propose it here as a fallback, asking the Court to revisit its propriety despite the reservations expressed in Zarrab. Those reservations, though admirably motivated and sincerely held, raise substantial equal protection concerns. They impair the statutory right to
of Denmark-from where defendant could not be extradited-charged with bulk cash smuggling and forfeiture, noting that the 9 This Court's opinion in Zarrab stands only for the proposition that wealthy defendants should not be provided an unfair advantage. It does not, of course, suggest that wealthy def
ing those goals in many prominent cases prosecuted in our Circuit, including cases against defendants as infamous as Bernie Madoff, Marc Dreier and David Brooks. To be clear, defense counsel are fully confident Mr. Epstein will appear as required without resort to this measure. And we understand and appreci
ot, of course, suggest that wealthy defendants should bear a special disadvantage. The facts supporting the Court's ruling of pretrial detention in Zarrab are easily distinguishable. The present case does not have national security implications, Mr. Epstein is a United States citizen (and does not poss
of Denmark-from where defendant could not be extradited-charged with bulk cash smuggling and forfeiture, noting that the 9 This Court's opinion in Zarrab stands only for the proposition that wealthy defendants should not be provided an unfair advantage. It does not, of course, suggest that wealthy def
ing those goals in many prominent cases prosecuted in our Circuit, including cases against defendants as infamous as Bernie Madoff, Marc Dreier and David Brooks. To be clear, defense counsel are fully confident Mr. Epstein will appear as required without resort to this measure. And we understand and appreci
of Denmark-from where defendant could not be extradited-charged with bulk cash smuggling and forfeiture, noting that the 9 This Court's opinion in Zarrab stands only for the proposition that wealthy defendants should not be provided an unfair advantage. It does not, of course, suggest that wealthy def
ot, of course, suggest that wealthy defendants should bear a special disadvantage. The facts supporting the Court's ruling of pretrial detention in Zarrab are easily distinguishable. The present case does not have national security implications, Mr. Epstein is a United States citizen (and does not poss
ing those goals in many prominent cases prosecuted in our Circuit, including cases against defendants as infamous as Bernie Madoff, Marc Dreier and David Brooks. To be clear, defense counsel are fully confident Mr. Epstein will appear as required without resort to this measure. And we understand and appreci
unding the practice, we respectfully propose it here as a fallback, asking the Court to revisit its propriety despite the reservations expressed in Zarrab. Those reservations, though admirably motivated and sincerely held, raise substantial equal protection concerns. They impair the statutory right to
of Denmark-from where defendant could not be extradited-charged with bulk cash smuggling and forfeiture, noting that the 9 This Court's opinion in Zarrab stands only for the proposition that wealthy defendants should not be provided an unfair advantage. It does not, of course, suggest that wealthy def
Entities connected to both David Brooks and Zarrab

Jeffrey Epstein
PERSON
United States
LOCATION
Prince Andrew
PERSON
Julie K. Brown
PERSON
New York
LOCATION
George W. Bush
PERSONMartin Weinberg
PERSONEmmy Taylor
PERSON
Department of Justice
ORGANIZATION
Harry Reid
PERSON
George Mitchell
PERSON
Marc Rich
PERSON
Barack Obama
PERSON
Michael Cohen
PERSONthe Southern District
LOCATIONLeon Black
PERSON
Geoffrey S. Berman
PERSON
Barry Diller
PERSON
Michael Jackson
PERSON
Alexander Acosta
PERSON