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the defendant should be housed where he can be secured at all times: a federal correctional center. The defendant faces a presumption of detention, Pretrial Services has recommended detention, and victims of the defendant seek his detention. Because there are no set of conditions short of incarceration that can
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 July 12, 2019 VIA ECF The Honorable Richard M. Berman United States District Court Southern
the defendant should be housed where he can be secured at all times: a federal correctional center. The defendant faces a presumption of detention, Pretrial Services has recommended detention, and victims of the defendant seek his detention. Because there are no set of conditions short of incarceration that can
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 July 12, 2019 VIA ECF The Honorable Richard M. Berman United States District Court Southern
the defendant should be housed where he can be secured at all times: a federal correctional center. The defendant faces a presumption of detention, Pretrial Services has recommended detention, and victims of the defendant seek his detention. Because there are no set of conditions short of incarceration that can
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 July 12, 2019 VIA ECF The Honorable Richard M. Berman United States District Court Southern
the defendant should be housed where he can be secured at all times: a federal correctional center. The defendant faces a presumption of detention, Pretrial Services has recommended detention, and victims of the defendant seek his detention. Because there are no set of conditions short of incarceration that can
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 July 12, 2019 VIA ECF The Honorable Richard M. Berman United States District Court Southern
the defendant should be housed where he can be secured at all times: a federal correctional center. The defendant faces a presumption of detention, Pretrial Services has recommended detention, and victims of the defendant seek his detention. Because there are no set of conditions short of incarceration that can
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 July 12, 2019 VIA ECF The Honorable Richard M. Berman United States District Court Southern
the defendant should be housed where he can be secured at all times: a federal correctional center. The defendant faces a presumption of detention, Pretrial Services has recommended detention, and victims of the defendant seek his detention. Because there are no set of conditions short of incarceration that can
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 July 12, 2019 VIA ECF The Honorable Richard M. Berman United States District Court Southern
the defendant should be housed where he can be secured at all times: a federal correctional center. The defendant faces a presumption of detention, Pretrial Services has recommended detention, and victims of the defendant seek his detention. Because there are no set of conditions short of incarceration that can
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 July 12, 2019 VIA ECF The Honorable Richard M. Berman United States District Court Southern
the defendant should be housed where he can be secured at all times: a federal correctional center. The defendant faces a presumption of detention, Pretrial Services has recommended detention, and victims of the defendant seek his detention. Because there are no set of conditions short of incarceration that can
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 July 12, 2019 VIA ECF The Honorable Richard M. Berman United States District Court Southern
the defendant should be housed where he can be secured at all times: a federal correctional center. The defendant faces a presumption of detention, Pretrial Services has recommended detention, and victims of the defendant seek his detention. Because there are no set of conditions short of incarceration that can
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 July 12, 2019 VIA ECF The Honorable Richard M. Berman United States District Court Southern
the defendant should be housed where he can be secured at all times: a federal correctional center. The defendant faces a presumption of detention, Pretrial Services has recommended detention, and victims of the defendant seek his detention. Because there are no set of conditions short of incarceration that can
Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 July 12, 2019 VIA ECF The Honorable Richard M. Berman United States District Court Southern
Entities connected to both Pretrial Services and The Silvio J. Mollo Building

Prince Andrew
PERSON
Department of Justice
ORGANIZATION
Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSONthe Southern District
LOCATION
United States
LOCATION
Michael Cohen
PERSON
Geoffrey S. Berman
PERSONSouthern District
LOCATIONFBI
ORGANIZATION
Audrey Strauss
PERSON
Southern District of New York
ORGANIZATIONMartin Weinberg
PERSON
Harry Reid
PERSONJeffrey Pagliuca
PERSON
New York
LOCATION
Michael Jackson
PERSON
Reid Weingarten
PERSON
U.S. Virgin Islands
LOCATIONCohen & Gresser LLP
ORGANIZATION