From: Lesley Groff
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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
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