Case 1:19-cr-00490-RMB Document 25 Filed 07/17/19 Page 1 of 2
Summary
Case 1:19-cr-00490-RMB Document 25 Filed 07/17/19 Page 1 of 2 Reid Weingarten 1114 Avenue of the Amencas www steptoe can July 17, 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, No. 19-cr-490 Dear Judge Berman: Steptoe STIPTO1 & JOHNSON LLP Pursuant to the Court's request and in further support of Mr. Epstein's bail submissions, attached are documents relating to Mr. Epstein's New Mexico registration status referenced in Mr. Epstein's July 16, 2019 letter supplementing his bail submission (Dkt.24). We thank the Court for its consideration and are pleased to provide any additional information the Court may need. Yours truly, /s Reid Weingarten Steptoe & Johnson, LLP (NYC) 1114 Avenue of the Americas New York, NY 10036 1 EFTA00105512 Case 1:19-cr-00490-RMB Document 25 Filed 07/17/19 Page 2 of 2 Martin G. We
Persons Referenced (6)
“...c vice) Martin G. Weinberg, P.C. 20 Park Plaza, Suite 1000 Boston, MA 02116 Marc Allan Fernich Law Office of Marc Fernich 810 Seventh Ave Suite 620 New York, NY 10019 2...”
Regina Chacon“...e contact Teresa Hernandez ats if you have any further questions. Sincerely, Regina Chacon, Accistant Bureau Chief Law Enforcement Records Bureau NM Department of Publi...”
Darren Indyke“...Epstein Subject: Date: September 14. 2012 at 10 13 PM To: Deborah Maya Cc: Darren Indyke out of an abundance of caution , i write to tell you that i arrived in new mex...”
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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
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 Vries. NY 10036 main direct www.stetocom 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 • JOHNSON LLP 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
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
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 212 506 3900 main 212 506 3955 direct www.steoloccorn nreeinoartenOsteotoe.com July 11, 2019 VIA ECF The Honorable Richard M. Berman United States District Court Southern District of New York United States Courthouse (212) 805-6715 500 Pearl Street New York, NY 10007 RE: United States v. Jeffrey Epstein, Criminal No. 19-490 Dear Judge Berman: Steptoe SttPtOt • JOHNSON ttP 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 nonprose
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
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