Epstein Secrets

ted States District Court Southern District of New York United States Courthouse 500 Pearl Street New York, New York 10007 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Judge Berman: The Government respectfully submits this letter in response to the defendant's Motion for Pretrial Release (t

a defendant who previously compared himself to a "person who steals a bagel" or a tragic mythical figure. See, e.g., Amber Southerland, Billionaire Jeffrey Epstein: I'm a sex offender, not a predator, N.Y. Post (2011) ("I'm not a sexual predator, I'm an "offender," the financier told The Post yesterday

y . . . .")—is equally irrelevant because the offense with which the defendant has been charged requires no such proof. See, e.g., United States v. Afrare, 632 F. App'x 272, 278 (6th Cir. 2016) ("We hold that § 1591(a) criminalizes the sex trafficking of children (less than 18 years old) with or withou

ation about Mr. Mitchell, other than that he is "Mr. Epstein's friend," his "close personal friend of decades

ted States District Court Southern District of New York United States Courthouse 500 Pearl Street New York, New York 10007 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Judge Berman: The Government respectfully submits this letter in response to the defendant's Motion for Pretrial Release (t

a defendant who previously compared himself to a "person who steals a bagel" or a tragic mythical figure. See, e.g., Amber Southerland, Billionaire Jeffrey Epstein: I'm a sex offender, not a predator, N.Y. Post (2011) ("I'm not a sexual predator, I'm an "offender," the financier told The Post yesterday

ant who previously compared himself to a "person who steals a bagel" or a tragic mythical figure. See, e.g., Amber Southerland, Billionaire Jeffrey Epstein: I'm a sex offender, not a predator, N.Y. Post (2011) ("I'm not a sexual predator, I'm an "offender," the financier told The Post yesterday. `It's t

y . . . .")—is equally irrelevant because the offense with which the defendant has been charged requires no such proof. See, e.g., United States v. Afrare, 632 F. App'x 272, 278 (6th Cir. 2016) ("We hold that § 1591(a) criminalizes the sex trafficking of children (less than 18 years old) with or withou

ation about Mr. Mitchell, other than that he is "Mr. Epstein's friend," his "close personal friend of decades

orable Richard M. Berman United States District Court Southern District of New York United States Courthouse July 12, 2019 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Judge Berman: The Government respectfully submits this letter in response to the defendant's Motion for Pretrial Rel

chard M. Berman United States District Court Southern District of New York United States Courthouse July 12, 2019 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Judge Berman: The Government respectfully submits this letter in response to the defendant's Motion for Pretrial Release (t

or, where victims are underage, the Government principally must prove that a minor is caused to engage in a commercial sex act. See United States v. Afrare, 632 F. App'x 272, 278 (6th Cir. 2016) ("We hold that § 1591(a) criminalizes the sex trafficking of children (less than 18 years old) with or witho