EFTA00028785.pdf

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pdf

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data-set-8

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Case 1:19-cr-00490-RMB Document 11 Filed 07/12/19 Page 1 of 14 
U.S. Department of Justice 
United States Attorney 
Southern District of New York 
The Silvio J. Mollo Building 
One Saint Andrew's Plaza 
New York. New York 10007 
July 12, 2019 
VIA ECF 
The Honorable Richard M. Berman 
United States District Court 
Southern District of New York 
United States Courthouse 
500 Pearl Street 
New York, New York 10007 
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). 
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 alleging that he sexually exploited dozens of 
minors, including girls as young as 14 years old, in New York and Florida. To this day, he is a 
registered sex offender designated by New York State in the highest category of risk to reoffend, 
despite unsuccessfully attempting to have that classification lowered. And any doubt that the 
defendant is unrepentant and unreformed was eliminated when law enforcement agents discovered 
hundreds or thousands of nude and seminude photographs of young females in his Manhattan 
mansion on the night of his arrest, more than a decade after he was first convicted of a sex crime 
involving a juvenile. 
The defendant also faces substantial evidence of his guilt, founded on the corroborated 
testimony of numerous victims, and this case presents the very real possibility that he will go to 
prison for the rest of his life. The defendant has at his disposal a vast fortune, the details of which 
remain largely concealed from the Court.…

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