U.S. Department of Justice United States Attorney Southern District of New York VIA ECF The Honorable Richard M. Berman United States District Court Southern District of New York United States Courthouse July 12, 2019 Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Judge Berman: The Government respectfully submits this letter in response to the defendant's Motion for Pretrial Release (the "Release Motion"), dated July 11, 2019 (Dkt. 6), and in further support of its Memorandum in Support of Detention (the "Detention Memo"), submitted to Magistrate Judge Pitman on July 8, 2019, which is attached hereto and incorporated herein (Ex. A). Simply put, the Release Motion misconstrues and misunderstands the relevant law, belittles and smears the many dozens of victims of the defendant's appalling sexual abuse, and utterly fails to meet its burden of rebutting the presumption that no condition or combination of conditions will reasonably assure the appearance of the defendant as required and the safety of the community. Rather than even attempting to address the grave risks of releasing a defendant with extraordinary financial resources, the defendant instead proposes a bail package that is effectively an unsecured bond masquerading as a 14-point plan. The Court should reject the defendant's application and order him detained pending trial. PRELIMINARY STATEMENT The defendant is a serial sexual predator who is charged with abusing underage girls for years. A grand jury has returned an indictment against him setting forth allegations that he abused dozens of minors, including girls as young as 14 years old, in multiple states. To this day, he is designated by New York State in the highest category of risk to reoffend, despite his attempts to lower that classification. And any doubt that he is unrepentant and unreformed was eliminated when law enforcement agents discovered a trove of nude images of young girls in his Manhattan mansio