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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
e 1:19-cr-00490-RMB Document 22 Filed 07/16/19 Page 6 of 9 Hon. Richard M. Berman July 16, 2019 Page 6 appropriate New Mexico official, Detective Deborah Anaya, when he spent any time at his ranch there. (The underlying documents are available upon request.) Sixth, though some studies may well indicate th
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
e 1:19-cr-00490-RMB Document 22 Filed 07/16/19 Page 6 of 9 Hon. Richard M. Berman July 16, 2019 Page 6 appropriate New Mexico official, Detective Deborah Anaya, when he spent any time at his ranch there. (The underlying documents are available upon request.) Sixth, though some studies may well indicate th
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
e 1:19-cr-00490-RMB Document 22 Filed 07/16/19 Page 6 of 9 Hon. Richard M. Berman July 16, 2019 Page 6 appropriate New Mexico official, Detective Deborah Anaya, when he spent any time at his ranch there. (The underlying documents are available upon request.) Sixth, though some studies may well indicate th
12 VIA EMAI AND FEDERAJ. EXPRESS Detective Deborah Anaya Office of the Santa Fe County Sheriff 35 Camino Justicia Santa Fe, NM 87508 Re: Mr. Jeffrey Epstein Dear Detective Anaya: As you may recall, the New Mexico Department of Public Safety determined that Mr. Jeffrey Epstein was not required to regist
ey Epstein was not required to register as a sex offender under NMSA 29-11A for his 2008 Florida conviction. You may also recall that, although Mr. Epstein's permanent residence is in the United States Virgin Islands, he does maintain a vacation home in Santa Fe County that he visits (albeit very infre
35 Camino Justicia Santa Fe, NM 87508 Re: Mr. Jeffrey Epstein Dear Detective Anaya: As you may recall
ts (albeit very infrequently), and, as a result, Mr. Epstein nevertheless registered with the Santa Fe County
Darren K. Indyke, PLLC 301 East 66th Street, 10B New York, Telephone Telecopier email: May 21, 2012 VIA EMAI AND FEDERAJ. EXPRESS Detective Deborah Anaya Office of the Santa Fe County Sheriff 35 Camino Justicia Santa Fe, NM 87508 Re: Mr. Jeffrey Epstein Dear Detective Anaya: As you may recall,
2 VIA EMAIL AND FEDERAL EXPRESS Detective Deborah Anaya Office of the Santa Fe County Sheriff 35 Camino Justicia Santa Fe, NM 87508 Re: Mr. Jeffrey Epstein Dear Detective Anaya: As you may recall, the New Mexico Department of Public Safety determined that Mr. Jeffrey Epstein was not required to regist
ey Epstein was not required to register as a sex offender under NMSA 29-11A for his 2008 Florida conviction. You may also recall that, although Mr. Epstein's permanent residence is in the United States Virgin Islands, he does maintain a vacation home in Santa Fe County that he visits (albeit very infre
35 Camino Justicia Santa Fe, NM 87508 Re: Mr. Jeffrey Epstein Dear Detective Anaya: As you may recall
ts (albeit very infrequently), and, as a result, Mr. Epstein attempted to register with the Santa Fe County S
arren K. Indyke, PLLC 301 East 66th Street, 1OB New York, Telephone: Telecopier email: May 21, 2012 VIA EMAIL AND FEDERAL EXPRESS Detective Deborah Anaya Office of the Santa Fe County Sheriff 35 Camino Justicia Santa Fe, NM 87508 Re: Mr. Jeffrey Epstein Dear Detective Anaya: As you may recall,
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
d M. Berman July 16, 2019 Page 6 caution and as an extra precaution, Epstein consistently notified the appropriate New Mexico official, Detective Deborah Anaya, when he spent any time at his residence there. (The underlying documents are available upon request.) Sixth, though some studies may well indicat
From: Deborah Anaya To: Jeffrey Epstein Subject: RE: Re: Date: Fri, 08 Jul 2011 17:09:52 +0000 /ff8 {-8 ( *"( p(ocr I-ARPT: 737943.411634: Rawh 0+@-44[0] 1 Valid * *48 I-08V"x09: [2MN0
From: Deborah Anaya To: Jeffrey Epstein Subject: RE: Re: Date: Fri, 08 Jul 2011 17:09:5
From: Deborah Anaya To: Jeffrey Epstein Subject: RE: Re: Date: Fri, 08 Jul 2011
From: Deborah Anaya To: Jeffrey Epstein Subject: RE: Re: Date: Fri, 08 Jul 2011 17:09:52 +0000 /ff8 {-8 ( *"( p(ocr I-ARPT: 737943.411634: Rawh 0+@-44[0] 1 Valid *
To: Deborah Anaya From: Jeffrey Epstein Sent Tue 7/30/2013 6:58:42 PM i will be in santa fe, from thurs aug Ito aug 31, hope you are well ***********************************************
To: Deborah Anaya From: Jeffrey Epstein Sent Tue 7/30/2013 6:58:42 PM i will be in san
To: Deborah Anaya From: Jeffrey Epstein Sent Tue 7/30/2013 6:58:42 PM i will b
To: Deborah Anaya From: Jeffrey Epstein Sent Tue 7/30/2013 6:58:42 PM i will be in santa fe, from thurs aug Ito aug 31, hope you are well ***********************
From: Deborah Anaya lIMII MI I Sent: Friday, July 8, 2011 5:10 PM To: Jeffrey Epstein Subject: RE: Re: /ff8 (-8 I-F8= ( If( Vu FARPT: 737943.411634: Rawh 2+@ 1 EFTA_R1_01434664 EFTA02399571 V[0] 1 Valid 48 F0rxQ9:12MN0 IMA/a?
Sent: Friday, July 8, 2011 5:10 PM To: Jeffrey Epstein Subject: RE: Re: /ff8 (-8 I-F8= ( If( Vu FARP
I MI I Sent: Friday, July 8, 2011 5:10 PM To: Jeffrey Epstein Subject: RE: Re: /ff8 (-8 I-F8= ( If(
From: Deborah Anaya lIMII MI I Sent: Friday, July 8, 2011 5:10 PM To: Jeffrey Epstein Subject: RE: Re: /ff8 (-8 I-F8= ( If( Vu FARPT: 737943.411634: Rawh 2+@ 1
n you get better, so that way I can stop by to validate the address during the work week. Thank you for notification Detective Deborah Anaya From: Jeffrey Epstein [mailto:[email protected]] Sent: Tuesday, March 08, 2011 8:17 AM To: Deborah Anaya Subject: im still here , at the ranch, sick with the flu..
ationttigmail.com[[email protected]]; Jeffrey Epstein[[email protected]] From: Deborah Anaya Sent
jeevacationttigmail.com[[email protected]]; Jeffrey Epstein[[email protected]] From: Deborah Ana
soon! Let me know when you get better, so that way I can stop by to validate the address during the work week. Thank you for notification Detective Deborah Anaya From: Jeffrey Epstein [mailto:[email protected]] Sent: Tuesday, March 08, 2011 8:17 AM To: Deborah Anaya Subject: im still here , at the ran
Entities connected to both Jeffrey Epstein and Deborah Anaya

Marc Rich
PERSONDarren Indyke
PERSON
Harry Reid
PERSON
Reid Weingarten
PERSONEmmy Taylor
PERSON
Geoffrey S. Berman
PERSON
Santa Fe
LOCATION
David Boies
PERSON
James Baker
PERSON
Richard Branson
PERSON
Supreme Court
ORGANIZATION
Hanson
PERSON
Richard M. Berman
PERSONGardner
PERSONSanta Fe County
LOCATIONPublic Safety Department
ORGANIZATIONFierro u. Taylor
PERSONJoel Podgor
PERSONSD Fla.
LOCATIONthe New Mexico Department of Public Safety
ORGANIZATION