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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
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
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
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
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
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
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
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
Entities connected to both Zarrab and Marc Dreier

Jeffrey Epstein
PERSON
United States
LOCATIONthe Southern District
LOCATION
Southern District of New York
ORGANIZATIONSecond Circuit
ORGANIZATIONBoustani
PERSON
Ghislaine Maxwell
PERSONPretrial Services
ORGANIZATION
Michael Cohen
PERSON
Department of Justice
ORGANIZATION
Bernie Madoff
PERSONKarni
PERSON
Michael Jackson
PERSON
Geoffrey S. Berman
PERSON
Harry Reid
PERSONMartin Weinberg
PERSONMorrison
PERSON
Reid Weingarten
PERSONFBI
ORGANIZATIONStroh
PERSON