EFTA00030247.pdf

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Source set: data-set-8

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U.S. Department of Justice
United States Attorney
Southern District of New York
VIA ECF
The Honorable Richard M. Berman
United States District Court
Southern District of New York
United States Courthouse
July 12, 2019
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
Pretrial Release (the "Release Motion"), dated July 11, 2019 (Dkt. 6), and in further support of its
Memorandum in Support of Detention (the "Detention Memo"), submitted to Magistrate Judge
Pitman on July 8, 2019, which is attached hereto and incorporated herein (Ex. A).
Simply put, the Release Motion misconstrues and misunderstands the relevant law, belittles
and smears the many dozens of victims of the defendant's appalling sexual abuse, and utterly fails
to meet its burden of rebutting the presumption that no condition or combination of conditions will
reasonably assure the appearance of the defendant as required and the safety of the community.
Rather than even attempting to address the grave risks of releasing a defendant with extraordinary
financial resources, the defendant instead proposes a bail package that is effectively an unsecured
bond masquerading as a 14-point plan. The Court should reject the defendant's application and
order him detained pending trial.
PRELIMINARY STATEMENT
The defendant is a serial sexual predator who is charged with abusing underage girls for
years. A grand jury has returned an indictment against him setting forth allegations that he abused
dozens of minors, including girls as young as 14 years old, in multiple states. To this day, he is
designated by New York State in the highest category of risk to reoffend, despite his attempts to
lower that classification. And any doubt that he is unrepentant and unreformed was eliminated
when law enforcement agents discovered a trove of nude images of young girls in his Manhattan
mansio…

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