010.pdf

Case 1:19-cr-00490-RMB Document 10 Filed 07/12/19 Page 1 of 2
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
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007

MEMO ENDORSED
p2

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

USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 7/12/19

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

Case 1:19-cr-00490-RMB Document 10 Filed 07/12/19 Page 2 of 2
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,

GEOFFREY S. BERMAN
United States Attorney

By: [Signature]
Alex Rossmiller / Alison Moe / Maurene Comey
Assistant United States Attorney
Southern District of New York
Tel: (212) 637-2415 / 2225 / 2324

Cc: Martin Weinberg, Esq., and Reid Weingarten, Esq., counsel for defendant

[Handwritten Box]
Application for extension of time denied. (Hard to imagine it would take the Govt extra time to review submission.)

SO ORDERED:
Date: 7/12/19
Richard M. Berman
Richard M. Berman, U.S.D.J.