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 nonprosecution agreement (the "NPA"). The government makes this drastic demand even though Mr. Epstein has never once attempted to flee the United States — despite a Florida federal judge's stated belief that he could void the NPA in appropriate circumstances, possibly threatening new charges there, and notwithstanding legally erroneous government assertions in ancillary litigation that Mr. Epstein was subject to potential prosecution in other federal judicial districts, including this one specifically. Indeed, Mr. Epstein feared the toxic political climate might tempt the government to try and end-run the NPA — yet continually returned home from travel abroad, fully prepared to vindicate his rights under the agreement and otherwise mount a full-throated defense. Finally, the government takes its extreme position in the teeth of Mr. Epstein's perfect compliance with onerous sex offender registration requirements — pinpointing his exact nightly whereabouts — across multiple jurisdicti