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Case 1:19-cr-00490-RMB Document7 - Filed 07/11/19 Pageiof3
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
)
)
UNITED STATES OF AMERICA )
)
v. )
) CRIMINAL NO. 19-CR-490
JEFFREY EPSTEIN, )
Defendant )
)
)
DEFENDANT JEFFREY EPSTEIN’S MOTION FOR LEAVE TO FILE
SUPPLEMENTAL FINANCIAL DISCLOSURE UNDER SEAL
Defendant Jeffrey Epstein, by and through undersigned counsel, hereby respectfully moves
this Honorable Court for leave to file under seal his supplemental financial disclosure. As noted in
Mr. Epstein’s bail submission, on advice of counsel, he has not yet provided a complete financial
disclosure. Counsel’s advice on this point was motivated by a desire to ensure the accuracy and
completeness of the information provided to the Court. Mr. Epstein seeks leave to file his
forthcoming supplemental disclosure under seal. As grounds and reasons therefor, Mr. Epstein relies
on the exceptional amount of publicity that has been generated by this case, much of which relates
specifically to his finances. Under the Bail Reform Act, financial information provided by a
defendant to a pretrial services officer “shall be used only for the purposes of a bail determination
and shall otherwise be confidential.” 18 U.S.C. § 3153(c)(1). Here, in the event Mr. Epstein is
required to publicly file his financial statement, the information contained therein will inevitably be
widely disseminated in the news media, contravening the statutory requirement of confidentiality.
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DOJ-OGR-00000320