Case 1:19-cr-00490-RMB

Document 7

Filed 07/11/19

Page 1 of 3

## UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA )

## V.

CRIMINAL NO. 19-CR-490

JEFFREY EPSTEIN,
Defendant

## 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, fmancial 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

EFTA00029302

Case 1:19-cr-00490-RMB

Document 7

Filed 07/11/19

Page 2 of 3

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

## Is/ Martin G. Weinberg

Martin G. Weinberg (application for
admission pro hac vice forthcoming)
20 Park Plaza, Suite 1000
Boston, MA 02116
(617) 227-3700
owlmgvv@att.net

## Is/ Marc Allan Fernich

Marc Allan Fernich
Law Office of Marc Fernich
810 Seventh Ave., Suite 620
New York, NY 10019
(212) 446-2346
maf®femichlaw.com

Dated: July 11, 2019

2

EFTA00029303

Case 1:19-cr-00490-RMB

Document 7

Filed 07/11/19

Page 3 of 3

## CERTIFICATE OF SERVICE

I, Reid Weingarten, hereby certify that on this date, July 11, 2019, a copy of the foregoing document has been served via Electronic Court Filing system on all registered participants.

is/ Reid Weingarten

3

EFTA00029304