Document 9

Case 1:19-cr-00490-RMB Document 9 Filed 07/11/19 Page 1 of 2 USDCSINY DOCUMENT ELECTRONICALLY FILED DOC#: DATE FILED: 7/11/19 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA v. JEFFREY EPSTEIN, Defendant MEMO ENDORSED CRIMINAL NO. 19-CR-490 DEFENDANT JEFFREY EPSTEIN'S MOTION FOR LEAVE TO FILE SUPPLEMENTAL FINANCIAL DISCLOSURE UNDER SEAL Defendant Jeffrey Epstein, by and through undersigned counsel, hereby respectfully moves this Honorable Court for leave to file under seal his supplemental financial disclosure. As noted in Mr. Epstein's bail submission, on advice of counsel, he has not yet provided a complete financial disclosure. Counsel's advice on this point was motivated by a desire to ensure the accuracy and completeness of the information provided to the Court. Mr. Epstein seeks leave to file his forthcoming supplemental disclosure under seal. As grounds and reasons therefor, Mr. Epstein relies on the exceptional amount of publicity that has been generated by this case, much of which relates specifically to his finances. Under the Bail Reform Act, financial information provided by a defendant to a pretrial services officer "shall be used only for the purposes of a bail determination and shall otherwise be confidential." 18 U.S.C. § 3153(c)(1). Here, in the event Mr. Epstein is required to publicly file his financial statement, the information contained therein will inevitably be widely disseminated in the news media, contravening the statutory requirement of confidentiality. 1 DOJ-OGR-00000325 --- PAGE BREAK --- Case 19-2221, Document 9, 08/05/2019, 26242022, Page1 of 1 ACKNOWLEDGMENT AND NOTICE OF APPEARANCE Short Title: United States of America v. Epstein Docket No.: 19-2221 Lead Counsel of Record (name/firm) or Pro se Party (name): Reid Weingarten / Steptoe & Johnson LLP Appearance for (party/designation): Defendant - Appellant Jeffrey Epstein DOCKET SHEET ACKNOWLEDGMENT/AMENDMENTS Caption as indicated is: (√) Correct ( ) Incorrect. See attached caption page with corrections. Appellate Designation is: (√) Correct ( ) Incorrect. The following parties do not wish to participate in this appeal: Parties: ____________________________________________________ ( ) Incorrect. Please change the following parties' designations: Party Correct Designation Contact Information for Lead Counsel/Pro Se Party is: (√) Correct ( ) Incorrect or Incomplete. As an e-filer, I have updated my contact information in the PACER "Manage My Account" screen. Name: ____________________________________________________ Firm: ____________________________________________________ Address: ____________________________________________________ Telephone: ____________________________________________________ Fax: ____________________________________________________ Email: ____________________________________________________ RELATED CASES (√) This case has not been before this Court previously. ( ) This case has been before this Court previously. The short title, docket number, and citation are: ____________________________________________________ ( ) Matters related to this appeal or involving the same issue have been or presently are before this Court. The short titles, docket numbers, and citations are: ____________________________________________________ CERTIFICATION I certify that (√) I am admitted to practice in this Court and, if required by LR 46.1(a)(2), have renewed my admission on ____________________________________________________ OR that ( ) I applied for admission on ____________________________________________________ or renewal on ____________________________________________________. If the Court has not yet admitted me or approved my renewal, I have completed Addendum A. Signature of Lead Counsel of Record: /s/ Reid Weingarten Type or Print Name: Reid Weingarten OR Signature of pro se litigant: ____________________________________________________ Type or Print Name: ____________________________________________________ ( ) I am a pro se litigant who is not an attorney. ( ) I am an incarcerated pro se litigant. DOJ-OGR-00000828 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 9 Filed 07/07/20 Page 1 of 2 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 July 7, 2020 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter in connection with the Court's Order dated July 6, 2020 (the "Order") (Dkt. 7) and the defendant's letter of July 6, 2020 (the "Defense Letter") (Dkt. 8). Pursuant to the Order, the parties have conferred regarding the scheduling of an initial proceeding in the above-captioned case. As set forth in the Defense Letter, the parties are available to proceed remotely on the morning of July 14, 2020. Additionally, the parties jointly respectfully propose the following briefing schedule in connection with the Government's Memorandum in Support of Detention, dated July 2, 2020 (Dkt. 4): - Defense response to be due by 3:00 p.m. on Friday, July 10, 2020 - Government reply to be due by 5:00 p.m. on Monday, July 13, 2020 The Government also respectfully renews and amends its request that the Court exclude time under the Speedy Trial Act, see Government Letter dated July 5, 2020 (Dkt. 5), between the defendant's arrest on July 2, 2020, and the revised proposed date of the arraignment, initial appearance, and bail hearing. In the interim, the Government intends to confer with defense counsel regarding the terms of a protective order and initial discovery, to facilitate the production DOJ-OGR-00001538 --- PAGE BREAK --- Case 20-3061, Document 9, 09/10/2020, 2927924, Page1 of 1 NOTICE OF APPEARANCE FOR SUBSTITUTE, ADDITIONAL, OR AMICUS COUNSEL Short Title: United States of America v. Ghislaine Maxwell Docket No.: No. 20-3061 Substitute, Additional, or Amicus Counsel's Contact Information is as follows: Name: Ty Gee Firm: Haddon, Morgan & Foreman, P.C. Address: 150 E. 10th Ave., Denver, CO 80203 Telephone: 303-831-7364 Fax: 303-832-2628 E-mail: tgee@hmflaw.com Appearance for: Defendant-Appellant Ghislaine Maxwell (party/designation) Select One: Substitute counsel (replacing lead counsel: ) (name/firm) Substitute counsel (replacing other counsel: ) (name/firm) Additional counsel (co-counsel with: Laura A. Menninger/Haddon, Morgan & Foreman, P.C. ) (name/firm) Amicus (in support of: ) (party/designation) CERTIFICATION I certify that: I am admitted to practice in this Court and, if required by Interim Local Rule 46.1(a)(2), have renewed my admission on OR I applied for admission on . Signature of Counsel: s/ Ty Gee Type or Print Name: Ty Gee DOJ-OGR-00019279 --- PAGE BREAK --- Case 1:19-cr-00490-RMB Document 9 Filed 07/11/19 Page 2 of 2 WHEREFORE, Mr. Epstein respectfully requests that this Honorable Court allow him leave to file his supplemental financial disclosure under seal. Respectfully Submitted, Jeffrey Epstein By His Attorneys, /s/ Reid Weingarten Reid Weingarten Steptoe & Johnson, LLP (NYC) 1114 Avenue of the Americas New York, NY 10036 (202)-506-3900 rweingarten@steptoe.com /s/ Martin G. Weinberg Martin G. Weinberg (application for admission pro hac vice forthcoming) 20 Park Plaza, Suite 1000 Boston, MA 02116 (617) 227-3700 owlingw@att.net /s/ Marc Allan Fernich Marc Allan Fernich Law Office of Marc Fernich 810 Seventh Ave., Suite 620 New York, NY 10019 (212) 446-2346 maf@fernichlaw.com Dated: July 11, 2019 Defense Motion granted. Materials to be hand delivered to chambers (and opposing counsel) by 9:00AM, July 12, 2019. SO ORDERED: Date: 7/11/19 Richard M. Berman, U.S.D.J. DOJ-OGR-0000326 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 9 Filed 07/07/20 Page 2 of 2 Honorable Alison J. Nathan July 7, 2020 Page 2 of discovery, which will serve the interests of justice by facilitating the timely production of discovery materials. See 18 U.S.C. § 3161(h)(1)(F). I have conferred with defense counsel, who consent to this request. Very truly yours, AUDREY STRAUSS Acting United States Attorney By: Alex Rossmiller / Alison Moe / Maurene Comey Assistant United States Attorneys Southern District of New York Tel: (212) 637-2415 Cc: Christian Everdell, Esq., and Mark Cohen, Esq., counsel for defendant DOJ-OGR-00001539