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516 KB

Extraction Summary

3
People
3
Organizations
2
Locations
2
Events
2
Relationships
3
Quotes

Document Information

Type: Legal correspondence / court filing
File Size: 516 KB
Summary

This document is the first page of a legal letter filed on July 16, 2019, by attorney Marc Fernich to Judge Richard M. Berman regarding the case US v. Epstein. The letter serves to supplement Jeffrey Epstein's request for bail in response to government arguments made the previous day. Fernich argues against the government's reliance on the 'rebuttable remand presumption' connected to 18 USC § 1591 charges, contending in a footnote that the statute does not cover the specific conduct at issue.

People (3)

Name Role Context
Marc Fernich Attorney
Author of the letter, representing Jeffrey Epstein.
Richard M. Berman Judge
Recipient of the letter, USDJ-SDNY.
Jeffrey Epstein Defendant
Subject of the bail request and criminal case.

Organizations (3)

Name Type Context
Law Office of Marc Fernich
Legal firm representing the defendant.
USDJ-SDNY
United States District Court for the Southern District of New York.
The Government
Refers to the prosecution/US Attorney's office.

Timeline (2 events)

July 15, 2019
Arguments made by the government regarding detention.
Court
The Government The Court
July 16, 2019
Filing of supplemental bail request letter.
SDNY

Locations (2)

Location Context
Address of the Law Office of Marc Fernich.
Address of the Court/Judge Berman.

Relationships (2)

Marc Fernich Attorney-Client Jeffrey Epstein
Fernich writes on behalf of Epstein regarding his bail request.
Marc Fernich Attorney-Judge Richard M. Berman
Formal legal correspondence addressed to the Judge.

Key Quotes (3)

"we write to supplement Jeffrey Epstein’s request for bail."
Source
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Quote #1
"Stripped to its core, the government’s position... distills to this: the nominally rebuttable remand presumption"
Source
DOJ-OGR-00000445.jpg
Quote #2
"Epstein contends that § 1591 and the concomitant remand presumption do not contemplate or cover the core conduct at issue here: performing sexual"
Source
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Quote #3

Full Extracted Text

Complete text extracted from the document (1,071 characters)

Case 1:19-cr-00490-RMB Document 24 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 Epstein’s
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-00000445

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