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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
perative presumption and make himself eligible for release. That cannot be the law. Such a construction turns the statute's massages for money. See Fierro u. Taylor, No. 11-CV8573, 2012 WL 13042630, at *3 (SDNY July 2, 2012) (holding that sex purchasers from minors fall outside § 1591's ambit). 2 E.g., 7/15/19
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
perative presumption and make himself eligible for release. That cannot be the law. Such a construction turns the statute's massages for money. See Fierro u. Taylor, No. 11-CV8573, 2012 WL 13042630, at *3 (SDNY July 2, 2012) (holding that sex purchasers from minors fall outside § 1591's ambit). 2 E.g., 7/15/19
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
perative presumption and make himself eligible for release. That cannot be the law. Such a construction turns the statute's massages for money. See Fierro u. Taylor, No. 11-CV8573, 2012 WL 13042630, at *3 (SDNY July 2, 2012) (holding that sex purchasers from minors fall outside § 1591's ambit). 2 E.g., 7/15/19
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
erson of Epstein's means could say, do or pledge to rebut the operative presumption and make himself eligible for release. massages for money. See Fierro u. Taylor, No. 11-CV8573, 2012 WL 13042630, at *3 (SDNY July 2, 2012) (holding that purchasers of sex from minors fall outside § 1591's ambit). 2 E.g., 7/15
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 →perative presumption and make himself eligible for release. That cannot be the law. Such a construction turns the statute's massages for money. See Fierro u. Taylor, No. 11-CV8573, 2012 WL 13042630, at *3 (SDNY July 2, 2012) (holding that sex purchasers from minors fall outside § 1591's ambit). 2 E.g., 7/15/19
Page: EFTA00014483 →the remand presumption. Third, as apparent from Mr. Epstein's initial financial disclosure, Mr. Epstein's fi
Page: EFTA00014485 →Entities connected to both Jeffrey Epstein and Fierro u. Taylor

Marc Rich
PERSON
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
Richard M. Berman
PERSONGardner
PERSONDeborah Anaya
PERSONPublic Safety Department
ORGANIZATIONJoel Podgor
PERSONSD Fla.
LOCATIONMartin Weintraub
PERSONBaker Tilly Virchow Krause
PERSONIra Mark & Tara Ellman
ORGANIZATIONAbout Sex Crime Statistics
ORGANIZATION