Epstein Secrets

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

ffective in meeting 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 under

s v. Esposito, 309 F. Supp. 3d 24 (S.D.N.Y. 2018); United States v. Seng, No. 15-CR-706, 2017 WL 2693625 (S.D.N.Y. Oct. 23, 2015); United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009); United States v. Madoff, 586 F. Supp. 2d 240 (S.D.N.Y. 2009); United States v. Schlegel, No. 06-CR-550, 2008

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

ffective in meeting 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 under

s v. Esposito, 309 F. Supp. 3d 24 (S.D.N.Y. 2018); United States v. Seng, No. 15-CR-706, 2017 WL 2693625 (S.D.N.Y. Oct. 23, 2015); United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009); United States v. Madoff, 586 F. Supp. 2d 240 (S.D.N.Y. 2009); United States v. Schlegel, No. 06-CR-550, 2008

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

ffective in meeting 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 under

s v. Esposito, 309 F. Supp. 3d 24 (S.D.N.Y. 2018); United States v. Seng, No. 15-CR-706, 2017 WL 2693625 (S.D.N.Y. Oct. 23, 2015); United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009); United States v. Madoff, 586 F. Supp. 2d 240 (S.D.N.Y. 2009); United States v. Schlegel, No. 06-CR-550, 2008

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

ffective in meeting 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 under

s v. Esposito, 309 F. Supp. 3d 24 (S.D.N.Y. 2018); United States v. Seng, No. 15-CR-706, 2017 WL 2693625 (S.D.N.Y. Oct. 23, 2015); United States v. Dreier, 596 F. Supp. 2d 831 (S.D.N.Y. 2009); United States v. Madoff, 586 F. Supp. 2d 240 (S.D.N.Y. 2009); United States v. Schlegel, No. 06-CR-550, 2008

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

at we did is we went through all the high profile cases in this courthouse in the past several years and other cases, cases like Medoff, cases like Dreier, cases like Esposito, where Judge Marrero ruled in 2018 relating to an alleged member of organized crime, and we went through those cases to find

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

at we did is we went through all the high profile cases in this courthouse in the past several years and other cases, cases like Medoff, cases like Dreier, cases like Esposito, where Judge Marrero ruled in 2018 relating to an alleged member of organized crime, and we went through those cases to find