USDC SDNY DOCUMENT ELECTRONICALLY FILED DOC #: ___ FOR TH_ DATE FILED: 7/11/19¶
UNITED STATES DISTRICT COURT THE SOUTHERN DISTRICT OF NEW YORK¶
UNITED STATES OF AMERICA¶
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.¶
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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 |
/s/ Martin G. Weinberg¶
Martin G. Weinberg (application for admission pro hac vice forthcoming)¶
20 Park Plaza, Suite 1000¶
Boston, MA 02116¶
Dated: July 11, 2019¶
/s Marc Allan Fernich¶
Marc Allan Fernich¶
Law Office of Marc Fernich¶
810 Seventh Ave., Suite 620¶
New York, NY 10019¶
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