5
Shared Docs
5
Same-Page
5 / 5
Mentions
t of New York United States Courthouse 500 Pearl Street New York, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman: Steptoe STEPTOE • JOHNSON LLP We write to outline the grounds entitling Jeffrey Epstein to pretrial release, proposing a stringent set of conditi
s not . . . require that foreign defendants be detained simply because their return cannot be guaranteed through extradition"); • United States v. Karni, 298 F. Supp. 2d 129 (D.D.C. 2004) (ordering release of defendant, an Israeli national who had resided in South Africa for the 18 years preceding h
nited States Courthouse (212) 805-6715 500 Pearl Street New York, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman: Steptoe ATCPTOC A JOiiNSON ..n We write to outline the grounds entitling Jeffrey Epstein to pretrial release, proposing a stringent set of condi
s not . . . require that foreign defendants be detained simply because their return cannot be guaranteed through extradition"); • United States v. Karni, 298 F. Supp. 2d 129 (D.D.C. 2004) (ordering release of defendant, an Israeli national who had resided in South Africa for the 18 years preceding h
nited States Courthouse (212) 805-6715 500 Pearl Street New York, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman: Steptoe SttPtOt • JOHNSON ttP We write to outline the grounds entitling Jeffrey Epstein to pretrial release, proposing a stringent set of condit
s not . . . require that foreign defendants be detained simply because their return cannot be guaranteed through extradition"); • United States v. Karni, 298 F. Supp. 2d 129 (D.D.C. 2004) (ordering release of defendant, an Israeli national who had resided in South Africa for the 18 years preceding h
t of New York United States Courthouse 500 Pearl Street New York, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman: Steptoe STEPTOE I JOHNSON UP We write to outline the grounds entitling Jeffrey Epstein to pretrial release, proposing a stringent set of conditi
s not . . . require that foreign defendants be detained simply because their return cannot be guaranteed through extradition"); • United States v. Karni, 298 F. Supp. 2d 129 (D.D.C. 2004) (ordering release of defendant, an Israeli national who had resided in South Africa for the 18 years preceding h
hat country. And finally, your Honor, with respect to the case law that defense has cited, they ignore the obvious comparator case, which is Judge Berman's decision regarding Jeffrey Epstein, who was arrested both on risk of flight grounds and on dangerousness grounds. And as Judge Berman detailed, t
Chen, 820 F. Supp. 1205 (N.D. Cal. 1992) 27 United States v. Cirillo, No. 99-1514, 1999 WL 1456536 (3d Cir. July 13, 1999) 26 United States v. Karni, 298 F. Supp. 2d 129 (D.D.C. 2004) 27 United States v Khashoggi, 717 F. Supp. 1048 (S.D.N.Y. 1989) 27 United States v. Lee, No. CR-99-1417 JP,
Entities connected to both Geoffrey S. Berman and Karni

Jeffrey Epstein
PERSON
Prince Andrew
PERSONthe Southern District
LOCATION
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSON
United States
LOCATIONFBI
ORGANIZATION
New York
LOCATIONSouthern District
LOCATION
Donald Trump
PERSONLeon Black
PERSONMartin Weinberg
PERSON
Stephen Hawking
PERSON
George W. Bush
PERSON
Julie K. Brown
PERSON
Michael Cohen
PERSON
Harry Reid
PERSON
Marc Rich
PERSON
Metropolitan Correctional Center
ORGANIZATION
Virginia Giuffre
PERSON