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 relates specifically to his finances. Under the Bail Reform Act, financial information provided by a defendant to a pretrial services officer "shall be used only for the purposes of a bail determination and shall otherwise be confidential." 18 U.S.C. § 3153(cX1). Here, in the event Mr. Epstein is required to publicly file his financial statement, the information contained therein will inevitably be widely disseminated in the news media, contravening the statutory requirement of confidentiality. 1 EFTA00100564 WHEREFORE, Mr. Epstein respectfully requests that this Honorable Court allow him leave to file his supplemental financial disclosure under seal. Respectfully Submitted, Jeffrey Epstein By His Attorneys, /s/ Reid Weingarten Reid Weingarten Steptoc & Johnson, LLP (NYC) 1114 Avenue of the Americas New York, NY 10036 /s/ Martin G. Weinberg Martin G. Weinberg (application for admission pro hoc vice forthcoming) 20 Park Plaza, Suite 1000 Boston. MA 02116 /s/ Marc Allan Fernich Marc Allan Femich Law Office of Marc Femich 810 Seventh Ave., Suite 620 New Yor NY 10019 Dated: July 11, 2019 2 "Poctis.ta mo+46) Irse#40. isit4ortish it it Komi Oft sa 4..),,,,iars (oaf glower touratai) 6r It:.oAist °Tay 14 ADM SO ORD E Date: 7 tt aptwittillatafaM Richard M. Berman, U.S.D.J. EFTA00100565