Epstein Secrets

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

pable reality emphatically proves he won't flee and entitles him to release — on any and all conditions the Court deems appropriate. 11 See, e.g., Doe u. US, CV 807-36 (SD Fla.). EFTA00068262 Case 1:19-cr-00490-RMB Document 22 Filed 07/16/19 Page 9 of 9 Hon. Richard M. Berman July 16, 2019 Page 9 W

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

pable reality emphatically proves he won't flee and entitles him to release — on any and all conditions the Court deems appropriate. 11 See, e.g., Doe u. US, CV 807-36 (SD Fla.). EFTA00073826 Case 1:19-cr-00490-RMB Document 22 Filed 07/16/19 Page 9 of 9 Hon. Richard M. Berman July 16, 2019 Page 9 W

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

pable reality emphatically proves he won't flee and entitles him to release — on any and all conditions the Court deems appropriate. 11 See, e.g., Doe u. US, CV 807-36 (SD Fla.). EFTA00073817 Case 1:19-cr-00490-RMB Document 22 Filed 07/16/19 Page 9 of 9 Hon. Richard M. Berman July 16, 2019 Page 9 W