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July 11, 2019
VIA ECF
The Honorable Richard M. Berman
United States District Court
Southern District of New York
United States Courthouse
500 Pearl Street
New York, New York 10007
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
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007
U.S. Department of Justice
United States Attorney
Southern District of New York
Case 1:19-cr-00490-RMB Document 8 Filed 07/11/19 Page 1 of 2