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Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 15 of 16

IV. Sixth Amendment

Finally, in a case such as this one, which will likely involve voluminous discovery and is predicated on events allegedly occurring 14 or more years ago, it is critical to counsel’s ability to provide effective assistance, as well as the defendant’s ability to meaningfully contribute to his defense, that Mr. Epstein be permitted pretrial release. The Sixth Amendment “does not provide merely that a defense shall be made for the accused; it grants to the accused personally the right to make his defense. It is the accused, not counsel, who must be ‘informed of the nature and cause of the accusation,’ and who must be ‘confronted with the witnesses against him,’ and who must be accorded ‘compulsory process for obtaining witnesses in his favor.’” Faretta v. California, 422 U.S. 806, 819 (1975). Given the unique circumstances of this case, Mr. Epstein’s exercise of these important Constitutional rights would be materially impaired by his pretrial detention.

V. Conclusion

Wherefore, for all of the foregoing reasons, Mr. Epstein respectfully submits that his conduct over the past 14 years proves that he poses no risk of flight or threat to the safety of the community. Even if the Court should have concerns to the contrary, there clearly exist a combination of conditions that would be sufficient to assure his presence as required and/or the safety of the community, including but not limited to some or all of the conditions proposed supra, or any other conditions the Court deems necessary and appropriate.

Yours truly,

Reid Weingarten
Steptoe & Johnson, LLP (NYC)
1114 Avenue of the Americas
New York, NY 10036
(202)-506-3900
Fax: (212)-506-3950
rweingarten@steptoe.com

Martin G. Weinberg (application for admission pro hac vice forthcoming)
Martin G. Weinberg, P.C.
20 Park Plaza, Suite 1000
Boston, MA 02116
(617) 227-3700
Fax: (617) 338-9538
owlmgw@att.net

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