A federal prosecutor's letter to Judge Richard Berman requesting more time to respond to Jeffrey Epstein's bail motion because the defense had failed to provide any financial disclosure as required.
This July 11, 2019 court filing is a letter from the U.S. Attorney's Office (Southern District of New York) to Judge Richard Berman regarding Jeffrey Epstein's bail proceedings. The Government expresses frustration that over three days after Epstein's initial presentment, and just hours before their deadline to respond to his bail motion, they still had not received any financial information from the defense. The letter requests an extension of at least 24 hours after receiving the financial disclosure to properly respond, and if necessary, asks for the bail hearing to be adjourned.

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Case 1:19-cr-00490-RMB Document 8 Filed 07/11/19 Page 1 of 2 U.S. Department of Justice United States Attorney Southern District of New York VIA ECF The Honorable Richard M. Berman United States District Court Southern District of New York United States Courthouse July 11, 2019 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Judge Berman: The Government respectfully submits this letter in response to the defendant's motion for leave to file a supplemental financial disclosure under seal (the "Sealing Motion") in connection with his motion for pretrial release (the "Bail Motion"). The Government takes no position on the defendant's application, but notes that as of this filing the Government still has not yet received any financial disclosure or information from the defense in connection with the defendant's application for bail. It is now more than three days following the defendant's initial presentment, more than seven hours after the defendant's deadline to file his Motion, and less than 24 hours before the Government's deadline to reply. There is no reason that the defendant need have waited until this evening to submit his Sealing Motion, and the Government cannot meaningfully respond to a Bail Motion that contains no material financial information, either under seal or otherwise. Accordingly, the Government respectfully requests that its deadline to respond to the defendant's Bail Motion be extended to at least 24 hours following the defendant's disclosure of any financial information upon which he intends to rely in connection with the Motion. Should EFTA00028418
Case 1:19-cr-00490-RMB Document 8 Filed 07/11/19 Page 2 of 2 Honorable Richard M. Berman United States District Judge July 11, 2019 Page 2 that require adjourning the bail hearing, the Government respectfully requests that the hearing be moved to a date and time convenient for the Court and sufficient to permit the Court to review the Government's reply. Very truly yours, GEOF REY S. BERMAN United tates Attorney By: Assistant United States Attorney Southern District of New York Cc: Martin Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant EFTA00028419




