EFTA00028082

EFTA00035425

EFTA00022361

Letter Motion

Letter Motion, USA v. Epstein, No. 1:19-cr-00490-1 (S.D.N.Y. Jul 15, 2019)

EFTA00028078

U.S. Department of Justice

U.S. Department of Justice United States Attorney Southern District of New York The Si!lo J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 July 8, 2019 VIA ECF The Honorable Henry Pitman 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 Pitman: The Government respectfully submits this letter in advance of the bail hearing scheduled for July 9, 2019, in the above-captioned case. For the reasons set forth herein, the Court should issue a permanent order of detention of the defendant; he cannot meet his burden of overcoming the presumption that there is no combination of conditions that would reasonably assure his continued appearance in this case or protect the safety of the community were he to be released. As set forth below, the charges in this case are exceptionally serious: the defendant is alleged to

U.S. Department of Justice

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 8, 2019 VIA ECF The Honorable Henry Pitman 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 Pitman: The Government respectfully submits this letter in advance of the bail hearing scheduled for July 8, 2019, in the above-captioned case. For the reasons set forth herein, the Court should order that the defendant be detained pending trial; he cannot meet his burden of overcoming the presumption that there is no combination of conditions that would reasonably assure his continued appearance in this case or protect the safety of the community were he to be released. As set forth below, the charges in this case are exceptionally serious: the defendant is alleged to be