DOJ-OGR-00000431.jpg

514 KB

Extraction Summary

3
People
4
Organizations
5
Locations
1
Events
3
Relationships
0
Quotes

Document Information

Type: Legal document
File Size: 514 KB
Summary

This is a legal letter dated July 16, 2019, from attorney Marc Fernich to Judge Richard M. Berman regarding the case of US v. Epstein. The letter serves to supplement Jeffrey Epstein's request for bail by countering the government's arguments for detention made in court the previous day. Fernich argues that the government's position relies on a remand presumption connected to 18 USC § 1591, which Epstein's defense contends does not apply to the core conduct at issue.

People (3)

Name Role Context
Marc Fernich Attorney
Author of the letter, from the Law Office of Marc Fernich, representing Jeffrey Epstein.
Richard M. Berman Judge (USDJ-SDNY)
Recipient of the letter, presiding judge in the case US v. Epstein.
Jeffrey Epstein Defendant
The defendant in the case US v. Epstein, on whose behalf the letter for bail is written.

Organizations (4)

Name Type Context
LAW OFFICE OF MARC FERNICH Law firm
The law firm representing Jeffrey Epstein, sending the letter.
USDJ-SDNY Court / Government agency
Stands for United States District Judge - Southern District of New York, the title and court of Judge Richard M. Berman.
The Court Court / Government agency
Mentioned as having made requests to which this letter is a response.
the government Government agency
Refers to the prosecution in the case of US v. Epstein, whose arguments for detention are being addressed.

Timeline (1 events)

2019-07-15
A court session where the government made arguments for detention and the Court made requests, referenced as 'yesterday' in the letter.
SDNY Court
The Court the government Jeffrey Epstein's legal team

Locations (5)

Location Context
State where Marc Fernich is also admitted to the bar.
Address of the Law Office of Marc Fernich.
Address of Judge Richard M. Berman's court.
Location of both the law office and the court.
Abbreviation for the Southern District of New York, the jurisdiction of the court case.

Relationships (3)

Marc Fernich Attorney-client Jeffrey Epstein
Marc Fernich is writing on behalf of Jeffrey Epstein to supplement his request for bail.
Marc Fernich Professional Richard M. Berman
Fernich, an attorney, is formally addressing Judge Berman regarding a case before his court.
Jeffrey Epstein Adversarial (legal) the government
The case is titled 'US v. Epstein', indicating Epstein is the defendant and the government is the prosecutor.

Full Extracted Text

Complete text extracted from the document (1,066 characters)

Case 1:19-cr-00490-RMB Document 22 Filed 07/16/19 Page 1 of 9
LAW OFFICE OF
MARC FERNICH
MARC FERNICH maf@fernichlaw.com
ALSO ADMITTED IN MASSACHUSETTS
810 SEVENTH AVENUE, SUITE 620
NEW YORK, NEW YORK 10019
212-446-2346
FAX: 212-459-2299
www.fernichlaw.com
July 16, 2019
BY ECF
Hon. Richard M. Berman
USDJ-SDNY
500 Pearl St.
New York, NY 10007
Re: US v. Epstein, 19 CR 490 (SDNY)
Dear Judge Berman:
In response to requests from the Court and certain arguments made
yesterday by the government, we write to supplement Jeffrey Epstein’s
request for bail.
First, make no mistake about the crux of the government’s
detention argument and its necessary implications. Stripped to its core,
the government’s position – as urged in its letters and echoed again
yesterday – distills to this: the nominally rebuttable remand
presumption (connected with 18 USC § 1591 charges) 1 plus Mr.
1 To be clear, Epstein contends that § 1591 and the concomitant remand presumption
do not contemplate or cover the core conduct at issue here: performing sexual
DOJ-OGR-00000431

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