Epstein Secrets

, Suite 1000 Boston, MAMA02116 15 EFTA00058443 Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 16 of 16 Marc Allan Fernich Law Office of Marc Fernich 810 Seventh Ave Suite 620 New York, NY 10019 16 EFTA00058444

stinctions — doing "equal right to the poor" and "rich" alike — are imperatives that run both ways. Id.

unding the practice, we respectfully propose it here as a fallback, asking the Court to revisit its propriety despite the reservations expressed in Zarrab. Those reservations, though admirably motivated and sincerely held, raise substantial equal protection concerns. They impair the statutory right to

of Denmark-from where defendant could not be extradited-charged with bulk cash smuggling and forfeiture, noting that the 9 This Court's opinion in Zarrab stands only for the proposition that wealthy defendants should not be provided an unfair advantage. It does not, of course, suggest that wealthy def

stinctions — doing "equal right to the poor" and "rich" alike — are imperatives that run both ways. Id.

(617) 338-9538 [email protected] 15 EFTA00076082 Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 16 of 16 Marc Allan Fernich Law Office of Marc Fernich 810 Seventh Ave Suite 620 New York, NY 10019 (212) 446-2346 Fax: (212)446 2330 [email protected] 16 EFTA00076083 Case 1:19-Cr-00400-RMS Doc

ot, of course, suggest that wealthy defendants should bear a special disadvantage. The facts supporting the Court's ruling of pretrial detention in Zarrab are easily distinguishable. The present case does not have national security implications, Mr. Epstein is a United States citizen (and does not poss

of Denmark-from where defendant could not be extradited-charged with bulk cash smuggling and forfeiture, noting that the 9 This Court's opinion in Zarrab stands only for the proposition that wealthy defendants should not be provided an unfair advantage. It does not, of course, suggest that wealthy def

United States Attorneys Martin G. Weinberg, PC Attorney for Defendant Steptoe & Johnson, LLP (NYC) Attorneys for Defendant BY: REID WEINGARTEN MARC FERNICH Attorney for Defendant JAMES BROCHIN Attorney for Defendant JOSEPH JAFFE Attorney for Defendant SOUTHERN DISTRICT REPORTERS, P.C. EFTA00079746

2.1 25 would have been charged is particularly rich in this case. There are plumes of smoke as to th

nd every opportunity to consult with that counsel while detained and while detained here. I'm not specifically familiar with the conditions of Mr. Zarrab's detention, but my general understanding is that there were concessions made with respect to his ability to review documents and have space. Thos

ly a challenging case. It's a significant case. This Court has significant experience with precisely that type of case with a detained defendant in Zarrab. In that. case, I think the Court saw -- and the country and the world saw -- that it is eminently possible for a defendant to have excellent, exce

United States Attorneys Martin G. Weinberg, PC Attorney for Defendant Steptoe & Johnson, LLP (NYC) Attorneys for Defendant BY: REID WEINGARTEN MARC FERNICH Attorney for Defendant JAMES BROCHIN Attorney for Defendant JOSEPH JAFFE Attorney for Defendant SOUTHERN DISTRICT REPORTERS, P.C. EFTA00095388

2.1 25 would have been charged is particularly rich in this case. There are plumes of smoke as to th

nd every opportunity to consult with that counsel while detained and while detained here. I'm not specifically familiar with the conditions of Mr. Zarrab's detention, but my general understanding is that there were concessions made with respect to his ability to review documents and have space. Thos

ly a challenging case. It's a significant case. This Court has significant experience with precisely that type of case with a detained defendant in Zarrab. In that. case, I think the Court saw -- and the country and the world saw -- that it is eminently possible for a defendant to have excellent, exce

ming) Martin G. Weinberg, P.C. 15 EFTA00095885 Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 16 of 16 Marc Allan Fernich Law Office of Marc Fernich I I I I I 16 EFTA00095886 Case 1:19-Cr-00400-RMS Document 6-1 Filed 07/11/19 Page 1 of 15 EXHIBIT 1 EFTA00095887 Case 1:19-cr-00490-RMB Docu

stinctions — doing "equal right to the poor" and "rich" alike — are imperatives that run both ways. Id.

of Denmark-from where defendant could not be extradited-charged with bulk cash smuggling and forfeiture, noting that the 9 This Court's opinion in Zarrab stands only for the proposition that wealthy defendants should not be provided an unfair advantage. It does not, of course, suggest that wealthy def

ot, of course, suggest that wealthy defendants should bear a special disadvantage. The facts supporting the Court's ruling of pretrial detention in Zarrab are easily distinguishable. The present case does not have national security implications, Mr. Epstein is a United States citizen (and does not poss

a, Suite 1000 Boston, MA 02116 15 EFTA00097474 Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 16 of 16 Marc Allan Fernich Law Office of Marc Fernich 810 Seventh Ave Suite 620 New York, NY 10019 16 EFTA00097475

stinctions — doing "equal right to the poor" and "rich" alike — are imperatives that run both ways. Id.

unding the practice, we respectfully propose it here as a fallback, asking the Court to revisit its propriety despite the reservations expressed in Zarrab. Those reservations, though admirably motivated and sincerely held, raise substantial equal protection concerns. They impair the statutory right to

of Denmark-from where defendant could not be extradited-charged with bulk cash smuggling and forfeiture, noting that the 9 This Court's opinion in Zarrab stands only for the proposition that wealthy defendants should not be provided an unfair advantage. It does not, of course, suggest that wealthy def

fairness that the law protects "the interests of rich and poor criminals in equal scale, and its hand

v. Banki, 369 F. App'x 152, 154 (2d Cir. 2010) (non- precedential summary order). " Smith v. Bennett, 365 U.S. 708, 714 (1961). 11 United States v. Zarrab, No. 15 CR 867, 2016 WL 3681423, at •13 (S.D.N.Y. June 16, 2016) (Richard M. Berman, J.). 7 EFTA00024839 --- PAGE BREAK --- Case 19-1018, Docum