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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.