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n United States District Court Southern District of New York United States Courthouse 500 Pearl Street New York, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman: Steptoe STEPTOE • JOHNSON LLP We write to outline the grounds entitling Jeffrey Epstein to pretrial releas
he relitigation of which is barred by a prior federal nonprosecution agreement (the "NPA"). The government makes this drastic demand even though Mr. Epstein has never once attempted to flee the United States — despite a Florida federal judge's stated belief that he could void the NPA in appropriate circ
Street New York, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman:
government makes this drastic demand even though Mr. Epstein has never once attempted to flee the United Stat
and the safety of any other person and the community." 18 U.S.C. § 3I42(c). "Only in rare circumstances should release be denied." United States v. Motamedi, 767 F.2d 1403, 1405 (9th Cir. 1985). Any doubts as to the propriety of release are resolved in the defendant's favor. See United States v. Chen, 8
n United States District Court Southern District of New York United States Courthouse 500 Pearl Street New York, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman: Steptoe STEPTOE I JOHNSON UP We write to outline the grounds entitling Jeffrey Epstein to pretrial releas
he relitigation of which is barred by a prior federal nonprosecution agreement (the "NPA"). The government makes this drastic demand even though Mr. Epstein has never once attempted to flee the United States — despite a Florida federal judge's stated belief that he could void the NPA in appropriate circ
Street New York, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman:
government makes this drastic demand even though Mr. Epstein has never once attempted to flee the United Stat
and the safety of any other person and the community." 18 U.S.C. § 3I42(c). "Only in rare circumstances should release be denied." United States v. Motamedi, 767 F.2d 1403, 1405 (9th Cir. 1985). Any doubts as to the propriety of release are resolved in the defendant's favor. See United States v. Chen, 8
HE INDICTMENT On April , 2008, a Grand Jury sitting in the Southern District of Florida returned a twenty-nine-count indictment charging defendant Jeffrey Epstein' with one count of conspiracy to use a means of interstate commerce to persuade, induce, or entice nineteen minors to engage in prostitution, in vio
under 18 years of age, in violation of 18 U.S.C. § 2423(b). Jane Does #1 through #19 were all minors at the time of their involvement with defendant Epstein. Jane Doe #11 was a resident of New York; the remaining Jane Does were all residents of Palm Beach County, Florida, at the time of their involvemen
all minors at the time of their involvement with defendant Epstein. Jane Doe #11 was a resident of New York; the re
FLORIDA Case No. UNITED STATES OF AMERICA vs. JEFFREY EPSTEIN, Defendant. Notice of Appeal From Magis
06 (2d . . 1985); United States I. Portes, 786 F. d 758, 765 (7thtir. 1985); United States Orta, 760 F.2d 887, 891 (8th Cir. 1985); United States Motamedi, 767 F.2d 140 , 1406 (9th Cir. 1985). 26.5 Detention hearing westlaw query 18 +S 3142(F) /P 26.2 OR JENCKS At a detention hearing, "the rules conc
s arrested on July 2, 2020 and since that date has been detained in jaw-droppingly appalling conditions. The government claims that Ms. Maxwell was Jeffrey Epstein's "associate" and helped him "groom" minors for sex back in the 1990s and early 2000s. Doc. 187. The indictment does not name these accusers and the
vnv.dailymail.co.ulc/news/ article-8444B7/Jeffrey-Epsteins-fugitive-madam-Ghislaine- Maxwell-hiding-lwcury-P
ed public outrage over the inexplicable death of Jeffrey Epstein, while in their custody. The "Epstein Ef
ire careful review of pretrial detention orders to ensure that the statutory mandate [of the Bail Reform Act] has been respected." United States v. Motamedi, 767 F.2d 1403, 1405 (9th Cir. 1985) (Kennedy, J.). Because the consequence of error — the unjust deprivation of liberty from an individual who is
Entities connected to both Jeffrey Epstein and Motamedi

Marc Rich
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George Mitchell
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George W. Bush
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United States
LOCATION
Harry Reid
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David Mitchell
PERSONJane Doe
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Department of Justice
ORGANIZATIONMartin Weinberg
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Alexander Acosta
PERSONthe Southern District
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New York
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Reid Weingarten
PERSONDoug Band
PERSONEmmy Taylor
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Michael Jackson
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Geoffrey S. Berman
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Colorado
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Bernie Sanders
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Southern District of New York
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