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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
rehensive forensic accounting of his finances as expeditiously as practicable. Joel Podgor, Partner Emeritus at prominent Manhattan accounting firm Baker Tilly Virchow Krause, LLP, has agreed to conduct the forensic investigation and prepare a report rapidly. As counsel said during the July 15 argument, Epstein will agre
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
rehensive forensic accounting of his finances as expeditiously as practicable. Joel Podgor, Partner Emeritus at prominent Manhattan accounting firm Baker Tilly Virchow Krause, LLP, has agreed to conduct the forensic investigation and prepare a report rapidly. As counsel said during the July 15 argument, Epstein will agre
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
rehensive forensic accounting of his finances as expeditiously as practicable. Joel Podgor, Partner Emeritus at prominent Manhattan accounting firm Baker Tilly Virchow Krause, LLP, has agreed to conduct the forensic investigation and prepare a report rapidly. As counsel said during the July 15 argument, Epstein will agre
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
rehensive forensic accounting of his finances as expeditiously as practicable. Joel Podgor, Partner Emeritus at prominent Manhattan accounting firm Baker Tilly Virchow Krause, LLP, has agreed to conduct the forensic investigation and prepare a report rapidly. As counsel said EFTA00126208 Case 1:19-cr-00490-RMB Document
Entities connected to both Jeffrey Epstein and Baker Tilly Virchow Krause

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
ORGANIZATIONFierro u. Taylor
PERSONJoel Podgor
PERSONSD Fla.
LOCATIONConstitutional Commentary
ORGANIZATIONIra Mark & Tara Ellman
ORGANIZATIONAbout Sex Crime Statistics
ORGANIZATION