USDC SDNY
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USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC ITED STATES DISTRICT COURT 1 SOUTHERN DISTRICT OF NEW YORK DATE FILED; ) ) UNITED STATES OF AMERICA ) ) v. ) ) JEFFREY EPSTEIN, ) Defendant ) ) ) MEMO ENDORSED DEFENDANT JEFFREY EPSTEIN'S MOTION FOR LEAVE TO FILE SUPPLEMENTAL FINANCIAL DISCLOSURE UNDER SEAL Defendant Jeffrey Epstein, by and through undersigned counsel, hereby respectfully moves this Honorable Court for leave to file under seal his supplemental financial disclosure. As noted in Mr. Epstein's bail submission, on advice of counsel, he has not yet provided a complete financial disclosure. Counsel's advice on this point was motivated by a desire to ensure the accuracy and completeness of the information provided to the Court. Mr. Epstein seeks leave to file his forthcoming supplemental disclosure under seal. As grounds and reasons therefor, Mr. Epstein relies on the exceptional amount of publicity that has been generated by this case, much of which
Persons Referenced (5)
“...e under seal. Respectfully Submitted, Jeffrey Epstein By His Attorneys, /8/ Reid Weingarten Reid Weingarten Steptoc & Johnson, LLP (NYC) 1114 Avenue of the Americas Ne...”
United States of AmericaUnited StatesMarc Allan Fernich“...20 Park Plaza, Suite 1000 Boston, MA 02116 (617) 227-3700 owlmgw@attnet /s/ Marc Allan Fernich Marc Allan Femich Law Office of Marc Femich 810 Seventh Ave., Suite 620 New...”
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EFTA DisclosureRelated Documents (6)
425 FEDERAL SUPPLEMENT, 3d SERIES
306 425 FEDERAL SUPPLEMENT, 3d SERIES t In short, the issue now before the Court has arisen only because Donziger unjustifi- ably has refused to comply with his discov- ery obligations. Had he done so — i.e., had he produced responsive documents as to which there was no colorable claim of priv- ilege, submitted a privilege log as to re- sponsive documents as to which there was such a colorable claim, and submitted any disputes for judicial resolution - there would be no need to examine his ESI. But he has not. And the Court thus must take appropriate action. His arguments to the contrary are meritless. Conclusion For the foregoing reasons, the Court has entered the protocol for imaging and forensic examination of Donziger's elec- tronic devices and media. SO ORDERED. the six months between being served with the document requests and the Court's eventual ruling, on October I8, 2018, that Donziger had waived any applicable privi- lege. Third, Donziger disregards the
USDC SDNY
USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC ITED STATES DISTRICT COURT 1 SOUTHERN DISTRICT OF NEW YORK DATE FILED; ) ) UNITED STATES OF AMERICA ) ) v. ) ) JEFFREY EPSTEIN, ) Defendant ) ) ) MEMO ENDORSED DEFENDANT JEFFREY EPSTEIN'S MOTION FOR LEAVE TO FILE SUPPLEMENTAL FINANCIAL DISCLOSURE UNDER SEAL Defendant Jeffrey Epstein, by and through undersigned counsel, hereby respectfully moves this Honorable Court for leave to file under seal his supplemental financial disclosure. As noted in Mr. Epstein's bail submission, on advice of counsel, he has not yet provided a complete financial disclosure. Counsel's advice on this point was motivated by a desire to ensure the accuracy and completeness of the information provided to the Court. Mr. Epstein seeks leave to file his forthcoming supplemental disclosure under seal. As grounds and reasons therefor, Mr. Epstein relies on the exceptional amount of publicity that has been generated by this case, much of which
425 FEDERAL SUPPLEMENT, 3d SERIES
306 425 FEDERAL SUPPLEMENT, 3d SERIES t In short, the issue now before the Court has arisen only because Donziger unjustifi- ably has refused to comply with his discov- ery obligations. Had he done so — i.e., had he produced responsive documents as to which there was no colorable claim of priv- ilege, submitted a privilege log as to re- sponsive documents as to which there was such a colorable claim, and submitted any disputes for judicial resolution - there would be no need to examine his ESI. But he has not. And the Court thus must take appropriate action. His arguments to the contrary are meritless. Conclusion For the foregoing reasons, the Court has entered the protocol for imaging and forensic examination of Donziger's elec- tronic devices and media. SO ORDERED. the six months between being served with the document requests and the Court's eventual ruling, on October I8, 2018, that Donziger had waived any applicable privi- lege. Third, Donziger disregards the
Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 1 of 16
Case 1:19-cr-00490-RMB Document 6 Filed 07/11/19 Page 1 of 16 Reid Weingarten 1114 Avenue of the Americas New York. NY 10036 WWW.StetO TI July 11, 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, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman: Steptoe STEPTOE I JOHNSON UP We write to outline the grounds entitling Jeffrey Epstein to pretrial release, proposing a stringent set of conditions that will effectively guarantee his appearance and abate any conceivable danger he's claimed to present. In essence, the government seeks to remand a self-made New York native and lifelong American resident based on dated allegations for which he was already convicted and punished — conduct the relitigation of which is barred by a prior federal nonprosecution agreement (the "NPA"). The government makes this drastic demand even though Mr
10/29/21, 10:54 AM
10/29/21, 10:54 AM SONY CMIECF NextGen Version 1.6 Query Reports Utilities Help Log Out CLOSED,ECF U.S. District Court Southern District of New York (Foley Square) CRIMINAL DOCKET FOR CASE #: 1:19-cr-00490-RMB All Defendants Case title: USA v. Epstein Date Filed: 07/02/2019 Date Terminated: 08/29/2019 Assigned to: Judge Richard M. Berman Appeals court case number: 19-2221 U.S.C.A. - 2nd Circ. Defendant (1) Jeffrey Epstein TERMINATED: 08/29/2019 also known as Sealed Defendant I TERMINATED: 08/29/2019 represented by James L. Brochin Steptoe & Johnson, LLP (NYC) 1114 Avenue of the Americas New York, NY 10036 Email: [email protected] LEAD ATTORNEY ATTORNEY TO BE NOTICED Designation: Retained Marc Allan Fernich Law Office of Marc Femich 810 Seveth Ave Suite 620 New York, NY 10019 Email: mal@:temichlaw.com LEAD ATTORNEY ATTORNEY TO BE NOTICED Designation: Retained Martin Gary Weinberg Martin G. Weinberg, PC 20 Park Plaza, Suite 1000 Boston
j782epsC kjc
j782epsC kjc UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNITED STATES OF AMERICA, v. JEFFREY EPSTEIN, Defendant. Before: x New York, N.Y. 19 Cr. 490(RMB) Conference July 8, 2019 1:20 p.m. HON. HENRY B. PITMAN, APPEARANCES GEOFFREY S. BERMAN United States Attorney for the Southern District of New York BY: Assistant United States Attorneys STEPTOE & JOHNSON, LLP Attorneys for Defendant BY: REID H. WEINGARTEN MARTIN G. WEINBERG Attorney for Defendant MARC FERNICH Attorney for Defendant Also Present: Special Agent Detective FBI , NYPD Magistrate Judge SOUTHERN DISTRICT REPORTERS, P.C. EFTA00080349 j782epsC kjc 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (Case called) THE DEPUTY CLERK: Counsel, please state your name for the record. MR. : Good afternoon, your Honor. For the government, , and With us are Special
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