Case 1:19-cr-00490-RMB Document 23 Filed 07/16/19 Page 1 of 3 U.S. Department of Justice United States Attorney Southern District of New York VIA ECF The Honorable Richard M. Berman United States District Judge Southern District of New York United States Courthouse 500 Pearl Street New York, New York 10007 The Silvio J. Mediu Building One Saint Andrew's Plaza New York. New York 10007 July 16, 2019 REQUEST TO FILE PARTIALLY UNDER SEAL Re: United States v. Jeffrey Epstein, 19 Cr. 490 (RMB) Dear Judge Berman: The Government respectfully submits this letter to provide the Court with additional information in response to the Court's questions at the detention hearing held on July 15, 2019 (the "Detention Hearing"). I. Payments to Potential Witnesses' In a July 12, 2019 letter, the Government informed the Court that the Government had recently obtained records from a financial institution ("Institution-1") that appeared to show the defendant had made suspicious payments shortly after the Miami Herald began publishing, on approximately November 28, 2018, a series of articles relating to the defendant, his alleged sexual misconduct, and the circumstances under which he entered into a non-prosecution agreement ("NPA") with the U.S. Attorney's Office for the Southern District of Florida in 2007. The same series highlighted the involvement of several of Epstein's former employees and associates in the alleged sexual abuse. At the Detention Hearing, the Court asked the Government to provide additional information about the individuals to whom these payments appear to have been made. First, records from Institution-1 show that on or about November 30, 2018, or two days after the series in the Miami Herald began, the defendant wired $100,000 from a trust account he controlled to , an individual named as a potential co-conspirator—and for whom Epstein obtained protection in—the NPA. This individual was also named and featured prominently in th