EFTA00028418.pdf

Type: pdf
Source set: data-set-8
Extracted text

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 
VIA ECF 
The Honorable Richard M. Berman 
United States District Court 
Southern District of New York 
United States Courthouse 
July 11, 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 
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 
EFTA00028418


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…
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