Epstein Secrets

Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 1 of 16 Reid Weingarten 1114 Avenue of the Americas New Vries. NY 10036 main direct www.stetocom July 11, 2019 VIA ECF The Honorable Richard M. Berman United States District Court Southern Dis

ed States v. Chen, 820 F. Supp. 1205, 1207 (N.D. Cal. 1992). Mr. Epstein's lone foreign residence is in Paris; France has an extradition treaty with the United States. 5 Mr. Epstein owns one private jet. He sold the other jet in June 2019. 4 EFTA00058432 Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 5

. Senior officials at the Department of Justice reviewed the NPA and either authorized or helped negotiate the resolution of the matter. See, e.g., United States' Second Supplemental Privilege Log filed as Dkt. 329-1 in Jane Doe #1 and Jane Doe #2 v. United States, No. 08-CV-80736 (S.D. Fla.) (the "CVRA litiga

08), modification denied, 2008 WL 11339654 (E.D.N.Y. July 2, 2008). See United States v. Esposito, 749 F. App'x 20 (2d Cir. 2018); United States v. Sablznani, 493 F.3d 63 (2d Cir. 2007). 10 EFTA00058438 Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 11 of 16 Other than his 2008 guilty plea pre

rrectly notes, federal prisoners should be detained in facilities run by trained personnel from federal correctional facilities." Id. at 258 (citing Sablznani, 493 F.3d at 74 n.13 ("To the extent [armed private guards] implies an expectation that deadly force may need to be used to assure defendant['s] pr

iction.") (citing United States v. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per curiam)). Moreover, any references in an NPA to the "Government" or the "United States" do not abrogate these principles. Annabi, 771 F.2d at 672 ("[A] plea agreement whereby a federal prosecutor agrees that 'the Government' will dism

ngs in this case or protect the safety of the community, and that any application for bail should be denied. Very truly yours, GEOF REY S. BERMAN United tates Attorney By: Assistant United States Attorney Southern District of New York Tel: (212) 637-2415 / 2225 / 2324 Cc: Martin Weinberg, Esq., and Re

's application for bail in part because home detention with electronic monitoring "at best . . . limits a fleeing defendant's head start"); see also United States v. Casteneda, No. 18 Cr. 047, 2018 WL 888744, at *9 (N.D. Cal. Feb. 2018) (same); United States v. Anderson, 384 F. Supp.2d 32, 41 (D.D.C. 2005) (sa

rrectly notes, federal prisoners should be detained in facilities run by trained personnel from federal correctional facilities." Id. at 258 (citing Sablznani, 493 F.3d at 74 n.13 ("To the extent [armed private guards] implies an expectation that deadly force may need to be used to assure defendant['s] pr

iction.") (citing United States v. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per curiam)). Moreover, any references in an NPA to the "Government" or the "United States" do not abrogate these principles. Annabi, 771 F.2d at 672 ("[A] plea agreement whereby a federal prosecutor agrees that 'the Government' will dism