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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
(212) 805-6715
500 Pearl Street
New York, NY 10007
RE:
United States v. Jeffrey Epstein, Criminal No. 19-490
Dear Judge Berman:
We write to outline the grounds entitling Jeffrey Epstein to pretrial release, proposing a
stringent set of conditions that will effectively guarantee his appearance and abate any
conceivable danger he’s claimed to present.
In essence, the government seeks to remand a self-made New York native and lifelong
American resident based on dated allegations for which he was already convicted and punished –
conduct the relitigation of which is barred by a prior federal nonprosecution agreement (the
“NPA”). The government makes this drastic demand even though Mr. Epstein has never once
attempted to flee the United States – despite a Florida federal judge’s stated belief that he could
void the NPA in appropriate circumstances, possibly threatening new charges there, and
notwithstanding legally erroneous government assertions in ancillary litigation that Mr. Epstein
was subject to potential prosecution in other federal judicial districts, including this one
specifically. Indeed, Mr. Epstein feared the toxic political climate might tempt the government to
try and end-run the NPA – yet continually returned home from travel abroad, fully prepared to
vindicate his rights under the agreement and otherwise mount a full-throated defense. Finally,
the government takes its extreme position in the teeth of Mr. Epstein’s perfect compliance with
onerous sex offender registration requirements – pinpointing his exact nightly whereabouts –
across multiple jurisdictions over a 10-year period.
Reid Weingarten
1114 Avenue of the Americas
New York, NY 10036
212 506 3900 main
212 506 3955 direct
www.steptoe.com
[email protected]
Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 1 of 16