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YORK. NEW YORK 10019 FAX: wwwlemichlaw.com July 16, 2019 BY ECF Hon. Richard M. Berman USDJ-SDNY 500 Pearl St. New York, NY 10007 Re: US v. Epstein, 19 CR 490 (SDNY) Dear Judge Berman: In response to requests from the Court and certain arguments made yesterday by the government, we write to su
90 (SDNY) Dear Judge Berman: In response to requests from the Court and certain arguments made yesterday by the government, we write to supplement Jeffrey Epstein's request for bail. First, make no mistake about the crux of the government's detention argument and its necessary implications. Stripped to its cor
sterday by the government, we write to supplement Jeffrey Epstein's request for bail. First, make no mist
the remand presumption. Third, as apparent from Mr. Epstein's initial financial disclosure, Mr. Epstein's fi
ainty that Epstein will appear as necessary. Fifth, in response to the Court's inquiry about Epstein's New Mexico registration status, the state's Public Safety Department formally advised in August 2010 that "you are not required to register with the State of New Mexico ... for your 2008 Florida conviction of Procuri
York, NY 10007 810 SEVENTH AVENUE, SUITE 620 NEW YORK. NEW YORK 10019 212-446-2346 FAX: 212-459-2299 wwwlemichlaw.com July 16, 2019 Re: US v. Epstein, 19 CR 490 (SDNY) Dear Judge Berman: In response to requests from the Court and certain arguments made yesterday by the government, we write to su
90 (SDNY) Dear Judge Berman: In response to requests from the Court and certain arguments made yesterday by the government, we write to supplement Jeffrey Epstein's request for bail. First, make no mistake about the crux of the government's detention argument and its necessary implications. Stripped to its cor
sterday by the government, we write to supplement Jeffrey Epstein's request for bail. First, make no mist
the remand presumption. Third, as apparent from Mr. Epstein's initial financial disclosure, Mr. Epstein's fi
ainty that Epstein will appear as necessary. Fifth, in response to the Court's inquiry about Epstein's New Mexico registration status, the state's Public Safety Department formally advised in August 2010 that "you are not required to register with the State of New Mexico ... for your 2008 Florida conviction of Procuri
York, NY 10007 810 SEVENTH AVENUE, SUITE 620 NEW YORK. NEW YORK 10019 212-446-2346 FAX: 212-459-2299 wwwlemichlaw.com July 16, 2019 Re: US v. Epstein, 19 CR 490 (SDNY) Dear Judge Berman: In response to requests from the Court and certain arguments made yesterday by the government, we write to su
90 (SDNY) Dear Judge Berman: In response to requests from the Court and certain arguments made yesterday by the government, we write to supplement Jeffrey Epstein's request for bail. First, make no mistake about the crux of the government's detention argument and its necessary implications. Stripped to its cor
sterday by the government, we write to supplement Jeffrey Epstein's request for bail. First, make no mist
the remand presumption. Third, as apparent from Mr. Epstein's initial financial disclosure, Mr. Epstein's fi
ainty that Epstein will appear as necessary. Fifth, in response to the Court's inquiry about Epstein's New Mexico registration status, the state's Public Safety Department formally advised in August 2010 that "you are not required to register with the State of New Mexico ... for your 2008 Florida conviction of Procuri
Jeffrey Epstein's net worth and finances. Any and all persons and/or entities identified through discovery having any knowledge of Defendant, Jeffrey Epstein's charitable, political or other donations made in the past. Any and all persons and/or entities identified through discovery that were sued i
are directed? ■., with the assistance of my attorney, Edwards, Esquire. Plaintiff objects to Defendant, Jeffre Epstein, having her address, as Mr. Epstein is a registered sex offender and . was a victim of his, and disclosure of her address could compromise her safety and privacy. 2. List the names
ncurred medical and psychological expenses in the past and will incur such expenses in the future. I have suffered a loss of earning capacity due to Jeffrey 15 EFTA00727698 Epstein's influence because I was encouraged by him as a minor child to enter a life of prostitution for him I suffered a loss
onally took me home on at least one occasion. or Defendant Epstein would call for me to go to his house and bring hi
ession, which are related to the abuse inflicted by Defendant, Jeffrey Epstein. 16 EFTA00727699 M.S. LMHC (Licensed Therapist) I FFI l ac cumty Public Safety Department Victim Services Division 205 North Dixie Highway Suite 5.1100 West Palm Beach, FL 33401 12. List the names and business addresses of all other
York, NY 10007 810 SEVENTH AVENUE, SUITE 620 NEW YORK. NEW YORK 10019 212-446-2346 FAX: 212-459-2299 wwwlemichlaw.com July 16, 2019 Re: US v. Epstein, 19 CR 490 (SDNY) Dear Judge Berman: In response to requests from the Court and certain arguments made yesterday by the government, we write to su
90 (SDNY) Dear Judge Berman: In response to requests from the Court and certain arguments made yesterday by the government, we write to supplement Jeffrey Epstein's request for bail. First, make no mistake about the crux of the government's detention argument and its necessary implications. Stripped to its cor
sterday by the government, we write to supplement Jeffrey Epstein's request for bail. First, make no mist
ainty that Epstein will appear as necessary. Fifth, in response to the Court's inquiry about Epstein's New Mexico registration status, the state's Public Safety Department formally advised in August 2010 that "you are not required to register with the State of New Mexico ... for your 2008 Florida conviction of Procuri
nt from chambers to defense counsel a short while ago. The relevant provision of their letter reads: Fifth, in response to the Court's inquiry about Epstein's New Mexico registration status, the state's Public Safety Department formally advised in August 2010 that "you are not required to register with
Page: EFTA00014480 →The relevant provision of their letter reads: Fifth, in response to the Court's inquiry about Epstein's New Mexico registration status, the state's Public Safety Department formally advised in August 2010 that "you are not required to register with the State of New Mexico ... for your 2008 Florida conviction of Procurin
Page: EFTA00014480 →York, NY 10007 810 SEVENTH AVENUE, SUITE 620 NEW YORK. NEW YORK 10019 212-446-2346 FAX: 212-459-2299 wwwlemichlaw.com July 16, 2019 Re: US v. Epstein, 19 CR 490 (SDNY) Dear Judge Berman: In response to requests from the Court and certain arguments made yesterday by the government, we write to su
Page: EFTA00014482 →sterday by the government, we write to supplement Jeffrey Epstein's request for bail. First, make no mistake abou
Page: EFTA00014482 →sterday by the government, we write to supplement Jeffrey Epstein's request for bail. First, make no mist
Page: EFTA00014482 →the remand presumption. Third, as apparent from Mr. Epstein's initial financial disclosure, Mr. Epstein's fi
Page: EFTA00014485 →ainty that Epstein will appear as necessary. Fifth, in response to the Court's inquiry about Epstein's New Mexico registration status, the state's Public Safety Department formally advised in August 2010 that "you are not required to register with the State of New Mexico ... for your 2008 Florida conviction of Procuri
Page: EFTA00014486 →Entities connected to both Jeffrey Epstein and Public Safety Department

Marc Rich
PERSON
United States
LOCATION
Harry Reid
PERSON
Reid Weingarten
PERSONEmmy Taylor
PERSON
Geoffrey S. Berman
PERSON
David Boies
PERSON
James Baker
PERSON
Richard Branson
PERSON
Supreme Court
ORGANIZATION
Hanson
PERSON
New Mexico
LOCATION
Richard M. Berman
PERSONGardner
PERSONVictim Services Division
ORGANIZATIONDeborah Anaya
PERSONJoel Podgor
PERSONFierro u. Taylor
PERSONSD Fla.
LOCATIONBaker Tilly Virchow Krause
PERSON