Case 1:19-cr-00490-RMB

Document 9

Filed 07/11/19

Page 1 of 2

USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #: <empty> FOR THE
DATE FILED: 7/11/19

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA

MEMO ENDORSED

V.

P2
CRIMINAL NO. 19-CR-490

JEFFREY EPSTEIN,
Defendant

## DEFENDANT JEFFREY EPSTEIN'S MOTION FOR LEA VE 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 infmmation provided to the Comt. Mr. Epstein seeks leave to file his fmthcoming 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 Ref01111 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 othe1wise be confidential." 18 U.S.C. § 3153(c)(l ). 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, contrnvening the statutmy requirement of confidentiality.

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Case 1:19-cr-00490-RMB

Document 9

Filed 07/11/19

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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,

## Isl  Reid Weingarten

Reid Weingarten
Steptoe & Jolmson, LLP  (NYC) 
1114 Avenue of the Americas
New York, NY 10036
(202)-506-3900 
1weingarten@stcptoe.com

## /s/ Martin G. Weinberg

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

## /s/ Marc Allan Fernich

Marc Allan Femich
Law Office of Marc Femich
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 opposite
counsel) by 9:00 A.M., July 12,
2019.

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SO ORDERED:
Date: 7/11/19
Richard M. Berman,
Richard M. Berman, U.S.D.J.
documents/doj-26a47132d48c21e0.pdf
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